Exhibit
14.1

WORLD
SERIES OF GOLF, INC.

CODE
OF BUSINESS CONDUCT AND ETHICS

(April
21, 2009)

Introduction

All
employees, officers and directors of World Series of Golf, Inc. (the Company)
are responsible for conducting themselves in compliance with this Code of
Business Conduct and Ethics (the Code), other policies of the Company and
applicable laws, rules and regulations. The Company adopted the Code in order
to assist the Company and its employees, officers and directors with the
Companys goals of conducting its business and affairs in accordance with
applicable laws, rules and regulations and maintaining the highest standards of
ethical conduct, fair dealing and honesty.

The
Company also expects that any consultants or other service providers it retains
will adhere to the Code. In addition, for purposes of Section 406 of the
Sarbanes-Oxley Act of 2002 and the rules of the Securities and Exchange
Commission (the Commission) promulgated thereunder, Sections I through IV of
the Code shall constitute the Companys code of ethics for Senior Financial
Officers (as defined in Section I below).

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|I. | Compliance
 and Reporting

Employees,
officers and directors should strive to identify and raise potential issues
before they lead to problems for the Company and should ask about the
application of the Code whenever there is a question as to whether a violation
of the Code has occurred or will occur. Any employee or officer who becomes
aware of any existing or potential violation of the Code should promptly notify
the appropriate supervisor. Should the Chief Executive Officer (CEO) or the
Principal Accounting Officer or any director become aware of an existing or
potential violation of the Code, he or she should promptly notify the Companys
Chief Financial Officer (CFO, and together with the CEO and the Principal
Accounting Officer, the Senior Financial Officers). The Company shall take
such disciplinary, corrective or preventative action as it deems appropriate to
address any existing or potential violation of this Code brought to its
attention.

Confidentiality
regarding those who make compliance reports and those potentially involved is
maintained to the extent possible during a compliance investigation. The Company
does not tolerate retribution, retaliation or adverse personnel action of any
kind against any person for lawfully reporting a situation of potential
noncompliance with the Code, or providing to the Company or any law enforcement
or other governmental agency any information or assistance relating to the
commission or possible commission of any federal or state offense.

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The
Senior Financial Officers have a responsibility to create an environment within
the Company in which compliance with the Code is treated as a serious
obligation and in which violations of the Code are not tolerated. The Senior
Financial Officers will establish and, if necessary, modify the procedures by
which violations of the Code are to be reported.

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|II. | Conflicts
 of Interest

All
business decisions must be made in the Companys best interest. A conflict of
interest arises when an individuals judgment is or may be influenced by
considerations of improper personal gain or benefit to the individual or another
person. Even if no actual conflict of interest occurs, situations that create
the appearance of a conflict may harm the Companys public relations or cause
other problems damaging to the Company, and, as such, also should be avoided.
Conflicts of interest are prohibited as a matter of Company policy, unless they
have been approved in advance by the Company.

For
example, an employee, officer or director must never use or attempt to use his
or her position at the Company to obtain any improper personal benefit for
himself or herself, for his or her family members or for any other person,
including loans or guarantees of obligations, from any other person or entity.
In this regard, service to the Company should never be subordinated to personal
gain and advantage. To the extent possible, conflicts of interest always should
be avoided. Any employee, officer or director who is aware of a material
transaction or relationship that could reasonably be expected to give rise to a
conflict of interest should promptly discuss the matter with the Chief
Financial Officer, or, at the request of the Chief Financial Officer, the
Companys outside legal counsel.

Transactions
with outside firms must be conducted within a framework established and controlled
by the executive level of the Company. Business dealings with outside firms
should not result in unusual gains for those firms or their employees. Unusual
gain refers to bribes, product bonuses, special fringe benefits, unusual price
breaks, and other windfalls designed to ultimately benefit either the outside
firm, its employee, or both. Promotional plans that could be interpreted to
involve unusual gain require specific executive-level approval.

An
actual or potential conflict of interest occurs when an employee is in a
position to influence a decision that may result in a personal gain for that
employee or for a relative as a result of the Companys business dealings. For
the purposes of this policy, a relative is any person who is related by blood
or marriage, or whose relationship with the employee is similar to that of
persons who are related by blood or marriage.

No
presumption of guilt is created by the mere existence of a relationship with
outside firms. However, if employees have any influence on transactions
involving purchases, contracts, or leases, it is imperative that they disclose
to an officer of the Company as soon as possible the existence of any actual or
potential conflict of interest so that safeguards can be established to protect
all parties.

Personal
gain may result not only in cases where an employee or relative has an
ownership interest in a firm with which the Company does business, but also
when an employee or relative receives any kickback, bribe, substantial gift or
special consideration from any

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Company tenant, customer or vendor (for example, a
contractor or supplier) or a potential tenant, customer or vendor. Any employee
who receives a gift from a tenant, customer or vendor or potential tenant,
customer or vendor must advise his or her supervisor immediately. If the
supervisor determines that the gift is of a normal and customary nature (e.g.,
not excessively expensive), the employee may retain the gift. If the gift is
determined by the supervisor to be excessive, the employee must return the gift
with a brief explanation that it is against the Companys policy for employees
to accept gifts of an excessive nature. Employees who do not report the receipt
of gifts to their immediate supervisor will be subject to disciplinary action
up to and including termination. In addition, employees who solicit gifts will
be subject to disciplinary action, up to and including termination.

In
addition, as a result of their close relationships to the Company and its
business, the Senior Financial Officers have a special responsibility to:

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| |  | refrain, without the approval of the Board of
 Directors, from transacting business with the Company through any entity in
 which the officer or a member of his or her immediate family owns all or a
 controlling interest;                                                                                                                                                                                            
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| |  | refrain, without the approval of the Board of
 Directors, from participating in other employment or serving as a director
 for other organizations if such activity reasonably could be expected to
 interfere with the officers ability to act in the best interests of the
 Company or reasonably could be expected to require the officer to use
 proprietary, confidential or non-public information of the Company;
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| |  | refuse gifts, favors or hospitality that would
 influence or appear to influence the recipient to act other than in the best
 interests of the Company; and                                                                                                                                                                                                                                                              
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| |  | report to the Audit Committee or to the Board of
 Directors any existing or potential director positions they hold, including
 positions on non-profit or charitable organization boards of directors.                                                                                                                                                                                                                   

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|III. | Public
 Disclosure

It
is the Companys policy that the information in its public communications and
disclosures, including its filings with the Commission, be full, fair,
accurate, timely and understandable. All employees, officers and directors who
are involved in the Companys disclosure process, including the Senior
Financial Officers, are responsible for acting in furtherance of this policy. Specifically,
these individuals are required to maintain familiarity with the disclosure
requirements applicable to the Company and are prohibited from knowingly
misrepresenting, omitting or causing others to misrepresent or omit, material
facts regarding the Company to others, whether within or outside the Company,
including the Companys independent accountants. In addition, any employee,
officer or director who has a supervisory role in the Companys disclosure
process has an obligation to diligently discharge his or her responsibilities.

The
Senior Financial Officers, in particular, must act in good faith and with due
care and diligence in connection with the preparation of the Companys public
disclosures. The Senior

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Financial Officers must ensure that the financial
statements and reports submitted to the Commission are full, fair, accurate,
timely and understandable. The Senior Financial Officers must also promptly
report any irregularities or deficiencies in the Companys internal controls
for financial reporting to the Audit Committee or the Board of Directors.

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|IV. | Compliance
 with Laws, Rules and Regulations

As
noted, it is the Companys policy to comply with all applicable laws, rules and
regulations. It is the personal responsibility of each employee, officer and
director to adhere to the standards and restrictions imposed by those laws,
rules and regulations.

It
is both illegal and against Company policy for any employee, officer or
director who is aware of material, nonpublic information relating to the
Company, any of the Companys customers or clients or any other private or
governmental issuer or securities to purchase or sell any securities of those
issuers, or recommend that another person purchase, sell or hold the securities
of those issuers.

In
general, information is material if it could affect a persons decision to
purchase, sell or hold a companys securities. Material information includes,
for example, a companys anticipated earnings, plans to acquire or sell
significant assets and changes in senior executives. Employees, officers and
directors should try to limit transactions to times when it can reasonably be
assumed that all material information about a company has been disclosed. All
employees, and officers and directors of the Company in particular, should
consult with the Chief Financial Officer, or, at the request of the Chief
Financial Officer, the Companys outside legal counsel, regarding the safest
times to trade in the Companys securities.

In
addition, employees, officers and directors may not disclose material,
nonpublic information about the Company or another company to any person (i)
inside the Company, unless they need to know the information for legitimate
business purposes, or (ii) outside of the Company, unless prior approval is
obtained from management in consultation with the Chief Financial Officer, or,
at the request of the Chief Financial Officer, the Companys outside legal
counsel. Bear in mind that this information belongs to the Company and no
person may misappropriate it for anyones benefit. Providing a tip based on
material, nonpublic information is unethical and illegal, and is prohibited,
even if you do not profit from it. All employees must obtain clearance from the
Chief Financial Officer prior to trading in the Companys securities.

More
detailed rules governing the trading of Company securities by employees,
officers and directors are set forth in the Companys Insider Trading Policy
most recently dated April 21, 2009. You may obtain a copy of this policy by
contacting the Chief Financial Officer.

Other
laws, rules, regulations and Company policies to which employees, officers and
directors are subject relate to business practices. For example, employees,
officers and directors may not misrepresent facts, contractual terms or Company
policies to a stockholder, service provider or regulator. Even if done
inadvertently, you must correct the misrepresentation as soon as possible after
consulting with the Chief Financial Officer, or, at the request of the Chief
Financial Officer, the Companys outside legal counsel. In addition, employees,
officers and

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directors must adhere to appropriate procedures
governing the retention and destruction of the Companys records, consistent
with applicable laws, regulations, Company policies and business needs. No
person should destroy, alter or falsify any document that may be relevant to a
threatened or pending lawsuit or governmental investigation. You should consult
with, and follow the instructions of, the Chief Financial Officer in these
situations.

Employees,
officers and directors must also comply with the U.S. Foreign Corrupt Practices
Act, which prohibits American businesses, and in many cases their foreign
subsidiaries, from offering, paying or authorizing payment to foreign
government officials, political parties or their officials, or political
candidates.

The
Senior Financial Officers, in particular, have a responsibility to ensure
compliance with the applicable rules and regulations of federal, state and
local governments, both domestic and foreign, and of appropriate public and
private regulatory agencies or organizations. In addition to adhering to
established Company policies and procedures, these individuals must take steps
to ensure that other employees and officers follow such policies and
procedures.

Any
employee, officer or director who is uncertain about the legal rules and regulations
to which he or she or the Company is subject should consult with the Chief
Financial Officer.

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|V. | Employment
 Practices

In
making employment and personnel decisions, the Company employment decisions
must be based only on an employees or applicants qualifications, demonstrated
skills and achievements without regard to race, color, sex, religion, national
origin, age, disability, veteran status, citizenship, sexual orientation,
gender identity or marital status.

All
employees are entitled to be treated with respect and dignity. Management must
not tolerate harassment of, or by, any employee in situations involving another
employee, stockholder, service provider or business associate. Employees,
officers and directors must not engage in conduct that could be construed as
sexual harassment, which may include, for example, unwelcome sexual advances,
offensive touching, sexually suggestive statements, offensive jokes, requests
for sexual favors or other verbal or physical conduct of a sexual nature.

Any
person who believes he or she has been harassed in the course of performing his
or her employment with the Company should notify the Chief Financial Officer.
Company policy prohibits retaliation against any individual who complains of,
or reports an instance of, harassment or participates in an investigation of a
harassment complaint.

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|VI. | Corporate
 Opportunities

Employees,
officers and directors owe a duty to the Company to advance the Companys
legitimate business interests when the opportunity to do so arises. In this
regard, employees, officers and directors are prohibited from (i) taking for
themselves personally (or directing to a third party) business opportunities
that are discovered through the use of Company property, information or
position (unless the Company has already been offered the opportunity and
rejected it); (ii) using Company property, information or position for improper
personal gain; and (iii) competing with the Company.

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It
may be difficult to decipher whether or not a particular personal benefit is
proper, as sometimes both personal and Company benefits may be derived from
certain activities. The best course of action in these circumstances is to
consult with the Chief Financial Officer, or, at the request of the Chief
Financial Officer, the Companys outside legal counsel.

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|VII. | Confidentiality

In
carrying out the Companys business, employees, officers and directors may
learn confidential or proprietary information about the Company or third
parties. Employees, officers and directors must maintain the confidentiality of
all information entrusted to them, except when disclosure is authorized or
legally mandated. Confidential or proprietary information includes, for
example, any nonpublic information concerning the Company, including its
business, properties, financial performance, results or prospects, and any
nonpublic information provided by a third party with the expectation or
contractual agreement that the information will be kept confidential and used
solely for the business purpose for which it was conveyed. Employees, officers
and directors are required to secure from unauthorized access and public view
documents under their control that contain confidential or proprietary
information. When such information is discarded, appropriate steps must be
taken to ensure proper and complete destruction.

In
addition, employees, officers and directors are prohibited from taking
confidential or proprietary information with them upon termination of
employment with the Company or from using or disclosing such information for
any purpose elsewhere, including with a different employer or company. Any
confidential or proprietary information must be promptly returned to the
Company upon termination of employment or affiliation with the Company.

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|VIII. | Fair
 Dealing

Company
policy is to conduct business fairly through honest business competition and
the Company does not seek competitive advantages through unethical or illegal
business practices. Each employee, officer and director should endeavor to deal
fairly with the Companys stockholders, service providers, competitors and
employees. No employee, officer or director should take unfair advantage of
anyone through manipulation, concealment, abuse of privileged information,
misrepresentation or omission of material facts or any other practice involving
unfair dealing.

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|IX. | Protection
 and Proper Use of Company Assets

All
employees, officers and directors should protect the Companys assets and
ensure their efficient use. It is important to bear in mind that theft,
carelessness and waste have a direct impact on the Companys profitability.
Thus, all assets of the Company should be used only for legitimate business
purposes.

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|X. | Waivers
 of the Code

The
Company may elect to waive certain provisions of the Code on a case-by-case
basis. Any employee, officer or director who would like to request a waiver of
one or more of the Codes provisions must discuss the matter with the Chief
Financial Officer. Waivers for

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executive officers and directors of the Company only
may be granted by the Board of Directors or a committee of the Board.

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|XI. | Specific
 Written Agreements

To
the extent there is any conflict or inconsistency between the provisions of
this Code of Business Conduct and Ethics and any specific written agreements
with the Company (which agreements are, have been or will be approved by the
Companys board of directors), the terms of such written agreements will
control the conduct of the parties and such conduct will not be considered to
be in conflict with any provisions of this Code of Business Conduct and Ethics.

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