SEC Comment Letter for iMedia Brands, Inc. (CIK 0000870826) — Oct 7, 2005
iMedia Brands, Inc. (CIK 0000870826)
Date: Oct. 7, 2005 · CIK: 0000870826 · Accession: 0000000000-05-051790
AI Filing Summary & Sentiment
File numbers found in text: 333-127040
Referenced dates: August 17, 2005
Letter
Mail Stop 3561 October 7, 2005 Nathan E. Fagre Senior Vice President and General Counsel ValueVision Media, Inc. 6740 Shady Oak Road Eden Prairie, MN 55344
Re: ValueVision Media, Inc. Amendment No. 1 to Registration Statement on Form S-3 Filed September 26, 2005 File No. 333-127040
Dear Mr. Fagre:
We have limited our review of your filing to those issues we have addressed in our 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 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.
Selling Shareholders, page 10 1. We note your response to comment 3 in our letter dated August 17, 2005. Please revise your disclosure to identify the selling shareholders who are affiliates of broker dealers and state that these selling stockholders purchased in the ordinary course of business and at the time of the purchase of the securities to be resold the selling stockholders had no agreements or understandings, directly or indirectly, with any person to distribute the securities.
******
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 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 Kurt Murao, Attorney Advisor, at (202) 551- 3338, Peggy Kim, Attorney Advisor, at (202) 551-3411 or me at (202) 551- 3720 with any other questions.
Sincerely,
H. Christopher Owings
Assistant Director
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Mail Stop 3561
October 7, 2005
Nathan E. Fagre
Senior Vice President and General Counsel
ValueVision Media, Inc.
6740 Shady Oak Road
Eden Prairie, MN 55344
Re: ValueVision Media, Inc.
Amendment No. 1 to Registration Statement on Form S-3
Filed September 26, 2005
File No. 333-127040
Dear Mr. Fagre:
We have limited our review of your filing to those issues we
have addressed in our 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 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.
Selling Shareholders, page 10
1. We note your response to comment 3 in our letter dated August
17,
2005. Please revise your disclosure to identify the selling
shareholders who are affiliates of broker dealers and state that
these selling stockholders purchased in the ordinary course of
business and at the time of the purchase of the securities to be
resold the selling stockholders had no agreements or
understandings,
directly or indirectly, with any person to distribute the
securities.
******
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 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 Kurt Murao, Attorney Advisor, at (202) 551-
3338,
Peggy Kim, Attorney Advisor, at (202) 551-3411 or me at (202) 551-
3720 with any other questions.
Sincerely,
H. Christopher Owings
Assistant Director
cc: James P. Beaubien, Esq.
Latham & Watkins LLP
Fax: (213) 891-8763
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Nathan E. Fagre
ValueVision Media, Inc.
October 7, 2005
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