SecProbe.io

Filing text and metadata
Intelligence Terminal Search Probe Scores Topics IPO Watchlist Monthly Activity About API

SEC Comment Letter for VIDEO DISPLAY CORP (VIDE) (CIK 0000758743) — Sep 12, 2005

VIDEO DISPLAY CORP (VIDE) (CIK 0000758743)
Date: Sept. 12, 2005 · CIK: 0000758743 · Accession: 0000000000-05-046930

AI Filing Summary & Sentiment

Referenced dates: August 1, 2005

Date
September 12, 2005
Author
David Burton
Form
UPLOAD
Company
VIDEO DISPLAY CORP (VIDE) (CIK 0000758743)

Letter

September 12, 2005 Via Facsimile and U.S. Mail Mr. Ronald D. Ordway Chief Executive Officer Video Display Corporation 1868 Tucker Industrial Drive Tucker, GA 30084

Re: Video Display Corporation Item 4.01 Form 8-K/A#1 Filed September 1, 2005 File No. 0-13394

Dear Mr. Ordway:

We have reviewed your filing and have the following comments. Where indicated, we think you should revise 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 detailed as necessary in your explanation. In some of our comments, we may ask you to provide us with more information so we may better understand your disclosure. After reviewing this information, we may 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 any other aspect of our review. Feel free to call us at the telephone numbers listed at the end of this letter.

Form 8-K/A#1 dated June 27, 2005

Item 4-01. Changes in Registrant`s Certifying Accountant

1. Please note that all responses provided to our comments should be filed on EDGAR, including your letter dated August 1, 2005. Please revise.

2. Please file an amendment to the Form 8-K to include disclosure of the actual effective date that BDO Seidman, LLP no longer provided services. We note that BDO Seidman, LLP would continue with services through the filing of the May 31, 2005 Form 10-Q (filed on July 15, 2005). Consequently, you must update all the disclosures in the Form 8-K through the effective date when services were completed.

3. To the extent that you amend the Form 8-K to comply with our comments, please obtain and file an updated Exhibit 16 letter from the former accountant stating whether the accountant agrees with your Item 304 disclosures, or the extent to which the accountant does not agree.

* * * *

As appropriate, please amend your filing and respond to these comments within five business days or tell us when you will provide us with a response. You may wish to provide us with marked copies of the amendment to expedite our review. Please furnish a cover 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 amendment 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 information required under the Securities Exchange Act of 1934 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.

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 disclosure 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 staff comments 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 our review of your filing or in response to our comments on your filing.

If you have any questions, please call me at (202) 551-3626.

Sincerely,
David Burton
Staff Accountant

Show Raw Text
<DOCUMENT>
<TYPE>LETTER
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>

Mail Stop 6010

      September 12, 2005

Via Facsimile and U.S. Mail

Mr. Ronald D. Ordway
Chief Executive Officer
Video Display Corporation
1868 Tucker Industrial Drive
Tucker, GA   30084

Re:	Video Display Corporation
	Item 4.01 Form 8-K/A#1
      Filed September 1, 2005
	File No. 0-13394

Dear Mr. Ordway:

      We have reviewed your filing and have the following
comments.
Where indicated, we think you should revise 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 detailed as necessary in your
explanation.
In some of our comments, we may ask you to provide us with more
information so we may better understand your disclosure.  After
reviewing this information, we may 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 any other aspect
of
our review.  Feel free to call us at the telephone numbers listed
at
the end of this letter.

Form 8-K/A#1 dated June 27, 2005

Item 4-01. Changes in Registrant`s Certifying Accountant

1. Please note that all responses provided to our comments should
be
filed on EDGAR, including your letter dated August 1, 2005.
Please
revise.

2. Please file an amendment to the Form 8-K to include disclosure
of
the actual effective date that BDO Seidman, LLP no longer provided
services.  We note that BDO Seidman, LLP would continue with
services
through the filing of the May 31, 2005 Form 10-Q (filed on July
15,
2005).  Consequently, you must update all the disclosures in the
Form
8-K through the effective date when services were completed.

3. To the extent that you amend the Form 8-K to comply with our
comments, please obtain and file an updated Exhibit 16 letter from
the former accountant stating whether the accountant agrees with
your
Item 304 disclosures, or the extent to which the accountant does
not
agree.

*    *    *    *

       As appropriate, please amend your filing and respond to
these
comments within five business days or tell us when you will
provide
us with a response.  You may wish to provide us with marked copies
of
the amendment to expedite our review.  Please furnish a cover
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 amendment 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 information required under the Securities
Exchange Act of 1934 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.

	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
disclosure 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 staff comments 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 our review of your filing or in
response to our comments on your filing.

	If you have any questions, please call me at (202) 551-3626.

							Sincerely,

							David Burton
							Staff Accountant

??

??

??

??

Mr. Ronald D. Ordway
Video Display Corporation
September 12, 2005
Page 3

</TEXT>
</DOCUMENT>