SEC Comment Letter for NATIONAL LAMPOON INC (CIK 0000798078) — Aug 26, 2005
NATIONAL LAMPOON INC (CIK 0000798078)
Date: Aug. 26, 2005 · CIK: 0000798078 · Accession: 0000000000-05-044463
AI Filing Summary & Sentiment
File numbers found in text: 333-123238
Letter
Mail Stop 3561 July 22, 2005 Daniel S. Laikin Chief Executive Officer 10850 Wilshire Boulevard, Suite 1000 Los Angeles, CA 90024
Re: National Lampoon, Inc. Amendment No. 3 to Registration Statement on Form SB-2 Filed on July 5, 2005 File No. 333-123238
Dear Mr. Laikin:
We have reviewed your filing, except for the financial statements, 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 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 numbers listed at the end of this letter.
Management`s Discussion and Analysis, page 33 National Lampoon Networks, page 33
1. Please file Springboard`s expert consent with your next amendment.
Results of Operations, page 37 Nine months ended April 30, 2005 as compared..., page 37
2. Revise this section to disclose the reasons for the significant increases in revenues among your four business segments. In addition to disclosing the amounts by which revenues increased in the different segments, you should disclose also why those revenues increased. Similarly, please analyze the significant expense increases for each of the four business segments.
Underwriting, page 77
3. Please disclose here the business experience of, and the material relationships you have with, Merriman Curhan. To the extent necessary, do the same for The Shemano Group. Refer to Item 508 of Regulation S-B.
Closing
As appropriate, please amend your registration 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 cover letter with your amendment that keys your responses to our comments and provides any requested supplemental 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.
Please contact Mathew C. Bazley at (202) 551-3382, or me, at (202) 551-3750 with questions.
Sincerely,
Max A. Webb
Assistant Director
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Mail Stop 3561
July 22, 2005
Daniel S. Laikin
Chief Executive Officer
10850 Wilshire Boulevard, Suite 1000
Los Angeles, CA 90024
Re: National Lampoon, Inc.
Amendment No. 3 to Registration Statement on Form SB-2
Filed on July 5, 2005
File No. 333-123238
Dear Mr. Laikin:
We have reviewed your filing, except for the financial
statements, 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 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 numbers
listed
at the end of this letter.
Management`s Discussion and Analysis, page 33
National Lampoon Networks, page 33
1. Please file Springboard`s expert consent with your next
amendment.
Results of Operations, page 37
Nine months ended April 30, 2005 as compared..., page 37
2. Revise this section to disclose the reasons for the significant
increases in revenues among your four business segments. In
addition
to disclosing the amounts by which revenues increased in the
different segments, you should disclose also why those revenues
increased. Similarly, please analyze the significant expense
increases for each of the four business segments.
Underwriting, page 77
3. Please disclose here the business experience of, and the
material
relationships you have with, Merriman Curhan. To the extent
necessary, do the same for The Shemano Group. Refer to Item 508
of
Regulation S-B.
Closing
As appropriate, please amend your registration 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
cover letter with your amendment that keys your responses to our
comments and provides any requested supplemental 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.
Please contact Mathew C. Bazley at (202) 551-3382, or me, at
(202) 551-3750 with questions.
Sincerely,
Max A. Webb
Assistant Director
cc: Via Facsimile: (310) 208-1154
Mary Ann Sapone
Richardson & Patel LLP
10900 Wilshire Boulevard, Suite 500
Los Angeles, CA 90024
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National Lampoon, Inc.
July 22, 2005
Page 1
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-3561
DIVISION OF
CORPORATION FINANCE
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