May 10, 2005

Mail Stop 0510

By U.S. mail and facsimile to (972) 447-0400

Mr. Kenneth Graham
Chief Executive Officer
International Debt Exchange Associates, Inc.
7531 Aberdon Road
Dallas, TX  75252

	RE:  	Form 8-K Item 4.01 filed April 25, 2005
		Form 8-K/A Item 4.01 filed May 3, 2005
		Form 8-K/A Item 4.01 filed May 10, 2005
		File # 000-50431

Dear Mr. Graham:

      We have reviewed your filings and have the following
additional comments.  If you disagree, we will consider your
explanation as to why our comments are inapplicable.  Please be
as
detailed as necessary in your explanation.  In some of our
comments, we may ask you to provide us with supplemental
information so we may better understand your disclosure.  After
reviewing this information, we may or may not raise additional
comments.

      Please understand that the purpose of our review 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
number
listed at the end of this letter.


1. Item 304(a)(1)(ii) of Regulation S-B requires a statement
whether the accountant`s report on the financial statements for
either of the past two years contained an adverse opinion or a
disclaimer of opinion or was qualified or modified as to
uncertainty, audit scope or accounting principles; and a
description of the nature of each such adverse opinion,
disclaimer
of opinion, modification or qualification.  This disclosure
should
refer to both reports.  In addition, please clarify if an audit
report was issued for the interim period of 2005.  If not, this
reference should be removed.

2. The disclosure should follow the language in Regulation S-B
(a)(1) and state whether during the registrant`s two most recent
fiscal years and any subsequent interim period through the date
of
resignation, declination or dismissal (actual date of change)
there
were any disagreements with the former accountant on any matter
of
accounting principles or practices, financial statement
disclosure,
or auditing scope or procedure, which disagreement(s), if not
resolved to the satisfaction of the former accountant, would
have
caused it to make reference to the subject matter of the
disagreement(s) in connection with its reports.

Exhibit 16:

3. To the extent that you make changes to the Form 8-K to comply
with our comments, please obtain and file an updated Exhibit 16
letter from the former accountants stating whether the
accountant
agrees with the statements made in your revised Form 8-K.



*  *  *  *  *


	We urge all persons who are responsible for the accuracy
and
adequacy of the disclosure in the filing reviewed by the staff
to
be certain that they have provided all information investors
require.  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 addition, please be advised that the Division of
Enforcement has access to all information you provide to the
staff
of the Division of Corporation Finance in our review of your
filing
or in response to our comments on your filing.

      Please file your supplemental response via EDGAR in
response
to these comments within 5 business days of the date of this
letter.  Please note that if you require longer than 5 business
days to respond, you should contact the staff immediately to
request additional time.  You may wish to provide us with marked
copies of each amended filing to expedite our review.  Direct
any
questions regarding the above to the undersigned at (202) 824-
5525.

								Sincerely,



								Ryan Rohn
								Staff Accountant
??

??

??

??

Mr. Kenneth Graham
International Debt Exchange Associates, Inc.
May 10, 2005
Page 1 of 2



UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-0510

         DIVISION OF
CORPORATION FINANCE