SEC Comment Letter for SCORES HOLDING CO INC (CIK 0000831489) — Aug 19, 2005
SCORES HOLDING CO INC (CIK 0000831489)
Date: Aug. 19, 2005 · CIK: 0000831489 · Accession: 0000000000-05-043095
AI Filing Summary & Sentiment
Letter
August 19, 2005 Via Facsimile and U.S. Mail 212-868-4414 David Silverman Treasurer, Chief Financial Officer Scores Holding Company, Inc. 533-535 West 27th Street New York, NY 10001
RE: Scores Holding Company, Inc. File No. 0-16665 Form 10-KSB for the fiscal year ended December 31, 2004
Dear Mr. Silverman:
We have reviewed the above referenced filing and have the following comments. We have limited our review to the financial statements and related disclosures included within this document. 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 filings.
Please expand or revise your disclosure as requested. If you disagree, we will consider your explanation as to why our comments are inapplicable or a revision is unnecessary. In some of our comments, we may ask you to provide us with additional information so we may better understand your disclosure. Please be as detailed as necessary in your explanations. We look forward to working with you in these respects and welcome any questions you may have about any aspects of our review.
Form 10-KSB for the fiscal year ended December 31, 2004
Note 4: Related Party Transactions, page F-14
1. We note that your receivable balance represents a significant portion of the revenue recorded in 2004. Tell us why you believe it was appropriate to initially recognize the revenue underlying these receivables, as collectibility should be reasonably assured prior to recognition. Also, tell us your basis for determining that the amount recorded as of December 31, 2004 is collectible.
2. We note that you have only collected $40,000 in cash on the promissory note from GoWest. Based upon the payment schedule on page F-14, this note appears delinquent. Provide us a collectibility analysis of this note as of December 31, 2004.
Other
3. We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filings reviewed by the staff to be certain that they have provided all information investors require. 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 filings; * staff comments or changes to disclosure in response to staff comments in the filings reviewed by the staff 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.
* * * *
Please file your response to our comments via EDGAR within fifteen business days from the date of this letter. Please understand that we may have additional comments after reviewing your response. You may contact Theresa Messinese at 202-551-3307 or the undersigned at 202-551-3812 with any questions.
Sincerely,
Michael Fay
Branch Chief
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<TEXT>
August 19, 2005
Via Facsimile and U.S. Mail 212-868-4414
David Silverman
Treasurer, Chief Financial Officer
Scores Holding Company, Inc.
533-535 West 27th Street
New York, NY 10001
RE: Scores Holding Company, Inc.
File No. 0-16665
Form 10-KSB for the fiscal year ended December 31, 2004
Dear Mr. Silverman:
We have reviewed the above referenced filing and have the
following comments. We have limited our review to the financial
statements and related disclosures included within this document.
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 filings.
Please expand or revise your disclosure as requested. If
you
disagree, we will consider your explanation as to why our comments
are inapplicable or a revision is unnecessary. In some of our
comments, we may ask you to provide us with additional information
so
we may better understand your disclosure. Please be as detailed
as
necessary in your explanations. We look forward to working with
you
in these respects and welcome any questions you may have about any
aspects of our review.
Form 10-KSB for the fiscal year ended December 31, 2004
Note 4: Related Party Transactions, page F-14
1. We note that your receivable balance represents a significant
portion of the revenue recorded in 2004. Tell us why you believe
it
was appropriate to initially recognize the revenue underlying
these
receivables, as collectibility should be reasonably assured prior
to
recognition. Also, tell us your basis for determining that the
amount recorded as of December 31, 2004 is collectible.
2. We note that you have only collected $40,000 in cash on the
promissory note from GoWest. Based upon the payment schedule on
page
F-14, this note appears delinquent. Provide us a collectibility
analysis of this note as of December 31, 2004.
Other
3. We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings reviewed by the staff to
be
certain that they have provided all information investors require.
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 filings;
* staff comments or changes to disclosure in response to staff
comments in the filings reviewed by the staff 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.
* * * *
Please file your response to our comments via EDGAR within
fifteen business days from the date of this letter. Please
understand that we may have additional comments after reviewing
your
response. You may contact Theresa Messinese at 202-551-3307 or
the
undersigned at 202-551-3812 with any questions.
Sincerely,
Michael Fay
Branch Chief
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Scores Holding Company, Inc.
August 19, 2005
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