SEC Comment Letter for SHARPER IMAGE CORP (CIK 0000811696) — Jun 15, 2005
SHARPER IMAGE CORP (CIK 0000811696)
Date: June 15, 2005 · CIK: 0000811696 · Accession: 0000000000-05-030285
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<TYPE>LETTER
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<FILENAME>filename1.txt
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Mail Stop 0308
June 15, 2005
Karen L. Luey
Plan Administrator
The Sharper Image 401(k) Savings Plan
650 Davis Street
San Francisco, CA 94111
RE: The Sharper Image 401(k) Savings Plan
Item 4.01 Form 8-K filed June 6, 2005
File No. 33-80504
Dear Ms Luey. :
We have reviewed your filing and have the following
comment. Where indicated, we think you should revise your
document
in response to these comment. 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.
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 comment or any other aspect
of
our review. Feel free to contact us at the telephone numbers
listed
at the end of this letter.
1. You disclose that you had no consultations with BDO Seidman
through September 17, 2004; however, you did not engage them until
May 31, 2005. Please revise to state that there were no
consultations with BDO Seidman through May 31, 2005, if true. See
Item 304(a)(2) of regulation S-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
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.
Karen Luey
The Sharper Image 401(k) Savings Plan
June 15, 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.
The amendment requested above should be filed within five
business days from the date of this letter or we should be advised
by
that date when it will be filed. Please file your response to
these
comments as an EDGAR correspondence file at the same time as you
file
the Form 8-K/A. Any questions regarding the above should be
directed
to Robert Burnett at (202) 551-3330, or in his absence, to Robert
Benton at (202) 551-3804.
Sincerely,
Michael Moran
Accounting Branch Chief
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