SecProbe.io

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

       DIVISION OF
CORPORATION FINANCE

Mail Stop 3720          September 18, 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. 2 to Registra tion Statement on Form S-4
  File No. 333-158336
  Filed September 10, 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.

Robert N. Fried
ID Arizona Corp.
September 18, 2009 Page 2  General

1. We note that you have added a new propos al to your registration statement
and proxy to approve an amendment to your amended and restated certificate of incorporation to provide conversion rights to a stockholder upon the approval of a business combination, re gardless of whether the stockholder
votes for or against the business comb ination.  This proposal represents a
fundamental change in the rights of your common stockholders such that the
decision as to whether to approve th is new proposal is a new investment
decision with respect to your common stock.  Please amend your registration
statement to register the offering of all shares of your common stock to reflect
the new investment decision for your comm on stockholders as a result of this
proposal.
 The Charter Amendment Proposal, page 83

2. Clarify why allowing a stockholder who elects  to convert to vote either yes or
no for the business combination is likely  to increase the likelihood that the
business combination will be approved.  We note that this amendment will effectively remove the 30% limit on converting stockholders.

3. Because the number of stockholders who elect to convert could dramatically
exceed 30%, discuss the potential nega tive effect on the liquidity of the
company’s stock following the business combination.  Discuss the likelihood
that the company might have very few public stockholders following the
business combination, and the ability of remaining stockholders to buy and
sell the company’s stock in the marketplace following the business combination.
 Ideation’s Reasons for the Business Combin ation and Recommendation of the Ideation
Board of Directors, page 107

4. We note that management assumed a 30%  conversion of Ideation stockholders
in calculating the price earnings rati o of 6.7x.  In light of your proposed
charter amendment and its effect of significantly increasing the potential
conversion percentage, discuss whether management considered revising its
price earnings ratio.  It would appear that the co nversion percentage could
reflect all public st ockholders converting.

Robert N. Fried
ID Arizona Corp.
September 18, 2009 Page 3  Acquisitions, Page F-51

5. We note in your response to comment ni ne that, for the numerators used in
your investment tests, you applied the best estimate of th e probable purchase
prices based on facts known to the Comp any as of the respective acquisition
dates for acquisitions with contingent consideration.  When determining the
significance of an acquisi tion under the investment test, you should include
any contingent consideration that represents additional purchase price as part of the total investment in the acquir ee unless the likelihood of its payment is
remote.  Your assessment of the likelihood of paying the contingent
consideration should reflect all inform ation known to management as of the
date of filing your Amended Form S-4.  With respect to each individual
acquisition consummated by the Company th at has an element of contingent
consideration, please provide us a revised test of significance  and explain, in
detail, your conclusions rega rding the amount of conti ngent consideration that
may possibly be paid.  Include in your explanation the amount of consideration that you have concluded to  be reasonably possible of being paid
and the amount that you have conclude d has a remote likelihood of being
paid, and explain why.

* * * *

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. September 18, 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) 551-3810, with any other questions.
       S i n c e r e l y ,          L a r r y  S p i r g e l        A s s i s t a n t  D i r e c t o r
cc: Teddy D. Klinghoffer, Esq. & Michael Francis, Esq.  Akerman Senterfitt  Via facsimile: (305) 374-5095