SecProbe.io

Mail Stop 3010
    December 23, 2009

Via U.S. Mail and Fax (770) 246-6401

Mr. Louis S. Friedman Chief Executive Officer WES Consulting, Inc. 2745 Bankers Industrial Drive Atlanta, GA  30360

Re: WES Consulting, Inc.
  Form 10-K and 10-K/A for the year ended December 31, 2008
  Filed February 2 8, 2009 and May 28, 2009
Forms 10-Q for the quarters en ded March 31, June 30 and
September 30, 2009 Filed May 14, 2009, August 14, 2009 a nd November 18, 2009
File No. 000-53314

Dear Mr. Friedman:
We have reviewed your above refere nced filings and have the following
comments.  Where indicated, we think you shoul d revise your documents in response to
these comments.  If you disagree, we will 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 on any other aspect of our
review.  Feel free to call us at the telephone numbers listed at the end of this letter.
 Form 10-Q for the period ended September 30, 2009

 Part 1. Financial Information, page 3

1. Please advise us why you have presented th e historical financial information of
Liberator, Inc. in your Form 10-Q for the quarter ended September 30, 2009,
given that the merger between WE S Consulting and Liberator was not

Mr. Louis S. Friedman
WES Consulting, Inc. December 23, 2009 Page 2
consummated until October 19, 2009.  It a ppears that you should have presented
the historical financial information of  WES Consulting, Inc. in your Form 10-Q
for the quarter ended September 30, 2009, with the merger described in a subsequent event footnote.  In order to avoid a lapse in repo rting, the historical
financial statements of Liberator for the quarter ended September 30, 2009 should
have been filed on Form 8-K not more than 45 days following the end of the period.  Furthermore, the Form 10-Q to be  filed for the quarter ended December
31, 2009 should reflect the operating resu lts of Liberator, including the
acquisition of WES Consulting from th e date the merger was consummated.

Consolidated Condensed Balance Sheets, page 3

2. In future filings, please distinguish the year end balance sheet information as
audited, if applicable.

Consolidated Condensed Statements of Operations, page 4
3. Please tell us and disclose in future fi lings the circumstances surrounding the gain
on forgiveness of debt recognized duri ng the quarter ended September 30, 2009.
4. Please advise us of your basis for reco rding expenses related to the reverse
acquisition as non-operating.

Note 1 – Organization and Nature of Business, page 6
5. Please define “Company” the first time that  it appears in your f iling, and revise to
use it consistently th roughout the document.

Note 9 – Commitments and Contingencies, page 12
 Common Stock Issuance, page 13

6. You disclose that Liberator acquired the majority of the i ssued and outstanding
common stock of WES Consulting on Sept ember 2, 2009.  You further disclose
that Liberator acquired an additional 972,000 shares (80.7%) of WES Consulting
on the closing date, which is defined as  October 19, 2009.  Please reconcile these
statements by clearly explaining the details of the transaction, including the role
of Belmont Partners LLC in future fili ngs.  Please provide us with your proposed
disclosure.

Mr. Louis S. Friedman
WES Consulting, Inc. December 23, 2009 Page 3  Note 11 – Equity, page 14

 Preferred Stock, page 14

7. Please clarify to us and in future filings whether the conversion of the Series A
Preferred Stock requires common shares i ssued upon conversion to be registered.
8. The comment above notwithstanding, pl ease tell us whether there are any
circumstances in which the registrant would be required to  cash settle the
conversion of the Series A Preferred Stock.

Warrants, page 15
9. We note that you consummated a reverse merger with OneUp Innovations during
fiscal 2009.  To the extent material, please include a discussion of this transaction
in future filings.

Note 12 – Related Parties, page 15
10. Please provide to us, and disclose in futu re filings, a reconciliation of the carrying
values of your related party notes.  It is unclear how the related party notes
payable described in this note agree to the carrying amounts recorded on your
balance sheet.

Exhibits 31.1 and 31.2
11. Please confirm that your principal executiv e and principal financial officer signed
the certifications in their own personal cap acity.  Also, in future filings, including
any amendments, please remove the title  of the certifying officer(s) in the
introductory paragraph of your certifications.  Please ensu re that the certifications
are in the exact form prescribed in  Item 601(B)(31) of Regulation S-K.
12. We note that you omitted the part of the introductory language in paragraph 4 of
your certification that refers to the ce rtifying officers’ responsibility for
establishing and maintaining internal control over financial reporting for the
company and paragraph 4(b).  Please am end your entire filing to include the
certification in the exact form prescribed  by Item 601(B)(31) of Regulation S-K.
Also, please see Question 246.13 of the Compliance and Disclosure Interpretations on Regulation S-K, which can be found at
http://www.sec.gov/divisions/corpf in/guidance/regs-kinterp.htm
, for reference.

*    *    *    *

Mr. Louis S. Friedman
WES Consulting, Inc. December 23, 2009 Page 4
As appropriate, please respond to these co mments within 10 business days or tell
us when you will provide us with a response.  Please furnish a cover letter with your
proposed revisions that keys your responses to our comments and provides any requested
supplemental information.  Detailed cover lett ers greatly facilitate  our review.  Please
understand that we may have additional commen ts after reviewing your responses to our
comments.

 We urge all persons who are responsible  for the accuracy and adequacy of the
disclosure in the filings to be certain that  the filings include all information required
under the Securities Exchange Act of 1934 and that they have provided all information
investors require for an informed 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.     In connection with responding to our comments, please provide, in writing, a
statement from the company acknowledging that
• the company is responsible for the adequacy  and accuracy of the disclosure in the
filings;

• staff comments or changes to disclosure  in response to staff comments do not
foreclose the Commission from taking any action with respect to the filings; and

• the company may not assert staff comme nts as a defense in any proceeding
initiated by the Commission or any person under the federal secu rities laws of the
United States.

In addition, please be advise d that the Division of Enfo rcement has access to all
information you provide to the staff of the Divi sion of Corporation Fi nance in our review
of your filings or in response to our comments on your filings.
 You may contact William Demarest at ( 202) 551-3432 or me at (202) 551-3429 if
you have questions.          S i n c e r e l y ,
 Kristi Marrone    Staff Accountant