SEC Comment Letter for EDUCATIONAL DEVELOPMENT CORP (EDUC) (CIK 0000031667) (EDUC) — Mar 11, 2005
EDUCATIONAL DEVELOPMENT CORP (EDUC) (CIK 0000031667)
Date: March 11, 2005 · CIK: 0000031667 · Accession: 0000000000-05-011666
AI Filing Summary & Sentiment
Letter
Mail Stop 0308 March 9, 2005 Randall W. White President and Chief Executive Officer Educational Development Corporation 10302 East 55th Place Tulsa, OK 74146-6515
RE: Educational Development Corporation Item 4.01 Form 8-K filed February 28, 2005 File No. 0-4957
Dear Mr. White:
We have reviewed the above referenced filing and have the following comments. We welcome any questions you may have about our comments. Feel free to contact us at the telephone numbers listed at the end of this letter.
1. You state that there were no disagreements with your former accountants through November 30, 2004. Please revise to state that there were no disagreements through February 22, 2005, if true. See Item 304(a)(1)(iv) of Regulation S-K. The disclosure with respect to consultations with your new auditor should also cover the interim period preceding their engagement. Please revise accordingly.
2. Please revise the first paragraph to state you dismissed Deloitte & Touche, if true. We do not believe the statement that you decided not to re-engage them satisfies the requirements of Item 304(a)(1)(i) of Regulation S-K. Please revise or advise.
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 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.
Educational Development Corporation March 9, 2005 Page 2
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 disclosures in the filing;
* staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; and
? the company may not assert this action as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
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 connection with our review of your filing or in response to our comments on your filing.
Please file your amendment within five business days from the date of this letter. The amendment should include an updated letter from your former accountants. The supplemental information we requested should be filed on EDGAR as correspondence. Any questions regarding the above should be directed to me at (202) 942-1809, or in my absence, to Robert Benton at (202) 942-1811.
Sincerely,
Robert Burnett
Staff Accountant
Show Raw Text
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Mail Stop 0308
March 9, 2005
Randall W. White
President and Chief Executive Officer
Educational Development Corporation
10302 East 55th Place
Tulsa, OK 74146-6515
RE: Educational Development Corporation
Item 4.01 Form 8-K filed February 28, 2005
File No. 0-4957
Dear Mr. White:
We have reviewed the above referenced filing and have the
following comments. We welcome any questions you may have about
our
comments. Feel free to contact us at the telephone numbers listed
at
the end of this letter.
1. You state that there were no disagreements with your former
accountants through November 30, 2004. Please revise to state
that
there were no disagreements through February 22, 2005, if true.
See
Item 304(a)(1)(iv) of Regulation S-K. The disclosure with respect
to
consultations with your new auditor should also cover the interim
period preceding their engagement. Please revise accordingly.
2. Please revise the first paragraph to state you dismissed
Deloitte
& Touche, if true. We do not believe the statement that you
decided
not to re-engage them satisfies the requirements of Item
304(a)(1)(i)
of Regulation S-K. Please revise or advise.
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
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.
Educational Development Corporation
March 9, 2005
Page 2
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
disclosures in the filing;
* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filing; and
? the company may not assert this action as a defense in any
proceeding initiated by the Commission or any person under the
federal securities laws of the United States.
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 connection with our review of
your
filing or in response to our comments on your filing.
Please file your amendment within five business days from
the
date of this letter. The amendment should include an updated
letter
from your former accountants. The supplemental information we
requested should be filed on EDGAR as correspondence. Any
questions
regarding the above should be directed to me at (202) 942-1809, or
in
my absence, to Robert Benton at (202) 942-1811.
Sincerely,
Robert Burnett
Staff Accountant
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