SecProbe.io

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

       DIVISION OF
CORPORATION FINANCE

Mail Stop 3720          July 27, 2009  Robert N. Fried President and Chief Executive Officer ID Arizona Corp. 1105 N. Market Street, Suite 1300 Wilmington, DE 19801
 Re: ID Arizona Corp.
  Amendment No. 1 to Registra tion Statement on Form S-4
  File No. 333-158336
  Filed July 15, 2009
Dear Mr. Fried:

We have reviewed the above filing an d have the following comments. Where
indicated, we think you should re vise your document in response to these comments.  If
you disagree, we will consider your explanation as to why our comment is inapplicable or
a revision is unnecessary.  Please be as deta iled as necessary in your explanation.  In
some of our comments, we may ask you to provi de us with information so we may better
understand your disclosure.  After reviewing th is information, we may or may not 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.
 General

1. Please update the financial informati on included in your filing for both
SearchMedia and Ideation in accordance w ith the requirements of Rule 8-02 of
Regulation S-X.
 Unaudited Pro Forma Combined Financial Statements, page 62

2.   Please tell us why you have not included pro forma adjustments giving effect to
SearchMedia’s recent significant acquisitions.

Robert N. Fried
ID Arizona Corp.
July 27, 2009 Page 2  Background of the Business Combination, page 91

 3. We note your response to prior comment 24 from our letter dated April 27, 2009.  Even though you believe that the letter would not serve any useful purpose to us or provide any material or  meaningful information, we would like to review the
letter of intent as part of our review process.  Please supplementally provide us
with a copy of the letter of intent.

4. We note your response to prior comment 25 from our letter dated April 27, 2009.
Please provide additional information on how the revised financial projections
differed from the December 2008 projections  and supplementally provide us with
the December 2008 projections and underlying assumptions.
 Legal Matters, page 225

 5. We note your response to prior comment 55 from our letter dated April 27, 2009.  In your response, you indicat e that you have filed a ll opinions of counsel
referenced in the Legal Matters section.  We note that a form of opinion from
Akerman Senterfitt has been filed as Exhibit 8.1.  Please file the legal opinion
from Arizona counsel as noted on your exhibit index.  In addition, you have not
yet filed, nor does your exhi bit index reference, an opinion from Jun He Law
Offices referenced in the Legal Matters se ction.  Please file all such exhibits as
soon as practicable and incl ude them and the applicable  consents in your exhibit
index.  We may have additional comments upon review of these exhibits.

Notes to Consolidated Financial Statements, page F-24

1. Principal activities, organization and basis of  presentation, page F-24

(b) Organization and basis of presentation, page F-24

6.   We note your response to prior comment  57 from our letter dated April 27, 2009.
Please confirm, if true, that at the tim e of the August 2007 repurchase of shares
from the legal owner of Conghui there wa s no contemplation of the dissolution of
the company’s arrangement with the le gal owner of Conghui in October 2007.

7.   You state that part of the Series B sh are placement proceeds were designated for
repurchase of shares from Conghui’s legal owner and that the consideration paid per share was based on a good faith and arms length negotiation between the
Series B investors and Conghui’s legal owner.  Please clar ify whether this
arrangement required the consent of the owners of Dale and/or Sige, who it
appears were the majority shareholders of the company at that time.  Also please explain why the company, if applicable, and the Series B investors agreed to this
designation, and how it benefite d the company and/or the Se ries B investors.  In

Robert N. Fried
ID Arizona Corp.
July 27, 2009 Page 3
that regard, it is unclear why the allocati on of proceeds from the sale of the Series
B shares would be of concern to the Series  B investors unless it affected the value
of the consideration they were required to pay.  Please advise us in detail.
 8. We note your response to prior comment 59 from our letter dated April 27, 2009.  Please disclose the amounts of cash dividends paid to the registrant for each of the
last three fiscal years, or since inception, by consolidated subsidiaries,
unconsolidated subsidiaries and 50 percen t or less owned persons accounted for
by the equity method.  Refer to Ru le 12-04(b) of Regulation S-X.
 3. Acquisitions, page F-34

 9. We note your response to prior comment 60 from our letter dated April 27, 2009.  Please tell us what financial statemen ts the company used to measure the
significance of SearchMedia’s recent acqui sitions and how they determined the
appropriate periods used for comparison.  Include re ference to authoritative
literature used as guidance.  Also conf irm for us, if true, that none of the
businesses acquired by SearchMedia dur ing 2008 met the significance conditions
in Rule 8-04(b) of Regulation S-X by 40% or more.

* * * *

As appropriate, please amend your regist ration statement in response to these
comments.  You may wish to provide us with 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 even t 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, acting pursuant to delegated
authority, declare the filing eff ective, it does not foreclose the
Commission from taking any action with respect to the filing;

Robert N. Fried
ID Arizona Corp. July 27, 2009 Page 4
• the action of the Commission or the st aff, 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 comments and the declaration of
effectiveness as a defense in any proceeding initiated by the Commission or any person under the fe deral 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.
We direct your attention to Rules 46 0 and 461 regarding requesting acceleration
of a registration statement.  Please allow ad equate time after the filing of any amendment
for further review before submitting a request for acceleration.  Please provide this request at least two business days in a dvance of the requested effective date.

You may contact Kenya Gumb s, Staff Accountant, at (202) 551-3373, or Robert
Littlepage, Accountant Branch Chief, at ( 202) 551-3361, if you have questions regarding
comments on the financial statements and re lated matters.  Please contact Scott Hodgdon,
Attorney-Adviser, at (202) 551-3273, or me, at (202) 551-3257, with any other questions.
       S i n c e r e l y ,          /s/ Celeste M. Murphy       L e g a l  B r a n c h  C h i e f
cc: Teddy D. Klinghoffer, Esq. & Michael Francis, Esq.  Akerman Senterfitt  Via facsimile: (305) 374-5095