SecProbe.io

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549

       DIVISION OF
CORPORATION FINANCE

  Mail Stop 3010

May 26, 2009
 Sanford H. Barber President WES Consulting, Inc. 3310 Stagecoach Trail Wimauma, FL  33598
Re: WES Consulting, Inc.
 Post Effective Amendment No. 1 on Form S-1  Filed May 13, 2009  File No. 333-141022

Dear Mr. Barber:

We have limited our review of your filing to those issues we have addressed in
our comments.  Where indicated, we think you should revise your document in response
to these comments.  If you disagree, we w ill consider your explanation as to why our
comment is inapplicable or a revision is unneces sary.  Please be as detailed as necessary
in your explanation.  In some of our comme nts, we may ask you to provide us with
information so we may better understand your  disclosure.  After reviewing this
information, we may raise additional comments.
Please understand that the purpose of our re view process is to assist you in your
compliance with the applicable disclosure  requirements and to  enhance the overall
disclosure in your filing.  We look forward to  working with you in these respects.  We
welcome any questions you may have about our  comments or any other aspect of our
review.  Feel free to call us at the telephone numbers listed at the end of this letter.
 Post-Effective Amendment No. 1 on Form S-1

 General

1. We note that your original registration st atement was declared effective on July 5,
2007 and included your audited financial st atements for the year ended December
31, 2006.  In that registration statemen t, you undertook to file post effective
amendments in order to update your prosp ectus pursuant to Section 10(a)(3) of
the Securities Act of 1933.  It appears th at your first Secti on 10(a)(3) update was

Sanford H. Barber
WES Consulting, Inc. May 26, 2009
Page 2

required by April 30, 2008.  Please provide us with a legal analysis of your
compliance with Sections 5 and 10(a )(3) of the Securities Act of 1933.
2. Please update your financial statements pu rsuant to Rule 8-08 of Regulation S-X.

Form 10-K for the fiscal year ended December 31, 2008
 Disclosure Controls and Procedures, page 24

3. Please disclose the conclusions of your principal executive and principal financial
officers, or persons performing similar f unctions, regarding the effectiveness your
disclosure controls and procedures.  Refer to Item 307 of Regulation S-K.

Exhibits
4. In exhibits 31.1 and 31.2 to your most rece nt Form 10-K, we note that you have
omitted paragraphs 4(d) of both exhibits.  In future filings, please provide the certifications in the exact form required by Item 601(b)(31)(i) of Regulation S-K.

* * * *

As appropriate, please amend your regist ration statement in response to these
comments.  You may wish to provide us w ith marked copies of the amendment to
expedite our review.  Please furnish a cove r letter with your amendment that keys your
responses to our comments and provides any requested information.  Detailed cover
letters greatly facilitate our review.  Please understand that we may have additional comments after reviewing your amendmen t and responses to our comments.
We urge all persons who are responsible for the accuracy and adequacy of the
disclosure in the filing to be certain that the filing includes all in formation required under
the Securities Act of 1933 and that they have  provided all information investors require
for an informed investment decision.  Since the company and its management are in possession of all facts relating to a company’ s disclosure, they are responsible for the
accuracy and adequacy of the disclosures they have made.       Notwithstanding our comments, in the ev ent the company requests acceleration of
the effective date of the pending registration statement, it should furnish a letter, at the
time of such request , acknowledging that:
 ‚ should the Commission or the staff, acti ng pursuant to delegated authority,
declare the filing effective, it does not foreclose the Commission from taking any
action with respect to the filing;

Sanford H. Barber
WES Consulting, Inc. May 26, 2009
Page 3

‚ the action of the Commission or the staff,  acting pursuant to delegated authority,
in declaring the filing effective, does not relieve the company from its full
responsibility for the adequacy  and accuracy of the disclosure in the filing; and
 ‚ the company may not assert staff comment s and the declaration of effectiveness
as a defense in any proceeding initiat ed by the Commission or any person under
the federal securities laws of the United States.
  In addition, please be advi sed that the Division of En forcement has access to all
information you provide to the staff of the Di vision of Corporation Finance in connection
with our review of your filing or in response to our comments on your filing.
We will consider a written request for acceleration of the effective date of the
registration statement as conf irmation of the fact that t hose requesting acceleration are
aware of their respective re sponsibilities under the S ecurities Act of 1933 and the
Securities Exchange Act of 1934 as they rela te to the proposed public offering of the
securities specified in the above registration statement.  We will act  on the request and,
pursuant to delegated authority, grant acce leration of the effective date.
Please contact Angela McHale at (202 ) 551-3402 or the undersigned at (202) 551-
3655 if you have any questions.

     S i n c e r e l y ,

 Sonia G. Barros
Special Counsel
     cc:   Justeene Blankenship ( via facsimile )
 Justeene Blankenship, PLLC  (801) 274-1099