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SEC Company Response from EZCORP INC (EZPW) (CIK 0000876523) (EZPW) — Dec 15, 2004

EZCORP INC (EZPW) (CIK 0000876523)
Date: Dec. 15, 2004 · CIK: 0000876523 · Accession: 0000899078-04-000804

AI Filing Summary & Sentiment

Referenced dates: November 12, 2004

Date
December 15, 2004
Author
/s/ Dan N. Tonissen
Form
CORRESP
Company
EZCORP INC (EZPW) (CIK 0000876523)

Letter

December 15, 2004 Securities and Exchange Commission Attn: Mr. Robert Burnett Mail Stop 3-8 Washington, D.C. 20549

Dear Mr. Burnett:

I received your letter dated November 12, 2004 regarding Item 4.01 of EZCORP, Inc.'s Form 8-K filed October 12, 2004. In bold italics below are the comments in your letter, and in plain text is our response.

I assume that our response will be held in confidence, subject only to disclosure pursuant to proper requests under the Freedom of Information Act ("FOIA"). I assume that any disclosure by the Staff of the information in this letter will comply with those procedures and request, as a courtesy, that you inform me if you become aware of any FOIA request regarding this response.

Staff Comments:

1. We believe that the facts indicated in your filing represents a future dismissal of Ernst & Young. You will need to file an amendment to this Form 8-K when Ernst & Young is no longer serving in any capacity as your principal accountant. The amended Form 8-K should disclose this date and state that there are still no disagreements, if true. The amendment should also include an updated letter from Ernst & Young indicating whether or not they agree with the disclosures in the amendment.

2. We suggest the amendment indicate you dismissed Ernst & Young rather than saying they were terminated. "Dismissed" is the term specified in Rule 3-04 of Regulation S-X.

Response: Ernst & Young's work as our principal accountant is now complete, and we have notified them of their dismissal as our principal accountant. On December 15, 2004, we filed the requested amendment to our Form 8-K, addressing the issues raised in your comments above.

We also acknowledge that:

o the Company is responsible for the adequacy and accuracy of the disclosures in the filing;

o 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

o 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.

Sincerely,
/s/ Dan N. Tonissen
Dan N. Tonissen
Senior Vice President, Chief Financial Officer, and Director

Show Raw Text
<DOCUMENT>
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<TEXT>
December 15, 2004

Securities and Exchange Commission
Attn:  Mr. Robert Burnett
Mail Stop 3-8
Washington, D.C.  20549

Dear Mr. Burnett:

I received your letter dated  November 12, 2004  regarding  Item 4.01 of EZCORP,
Inc.'s Form 8-K filed  October 12, 2004.  In bold italics below are the comments
in your letter, and in plain text is our response.

I  assume  that  our  response  will  be  held in  confidence,  subject  only to
disclosure  pursuant to proper  requests  under the Freedom of  Information  Act
("FOIA").  I assume that any disclosure by the Staff of the  information in this
letter will comply with those  procedures and request,  as a courtesy,  that you
inform me if you become aware of any FOIA request regarding this response.

Staff Comments:

     1.   We believe that the facts indicated in your filing represents a future
          dismissal of Ernst & Young. You will need to file an amendment to this
          Form 8-K when Ernst & Young is no longer  serving in any  capacity  as
          your principal  accountant.  The amended Form 8-K should disclose this
          date and state that  there are still no  disagreements,  if true.  The
          amendment  should  also  include an updated  letter from Ernst & Young
          indicating  whether  or not they  agree  with the  disclosures  in the
          amendment.

     2.   We suggest the amendment  indicate you dismissed  Ernst & Young rather
          than saying they were terminated. "Dismissed" is the term specified in
          Rule 3-04 of Regulation S-X.

Response:  Ernst & Young's work as our principal accountant is now complete, and
we have  notified  them of  their  dismissal  as our  principal  accountant.  On
December 15, 2004, we filed the requested  amendment to our Form 8-K, addressing
the issues raised in your comments above.

We also acknowledge that:

     o    the  Company is  responsible  for the  adequacy  and  accuracy  of the
          disclosures in the filing;

     o    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

     o    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.

Sincerely,

/s/  Dan N. Tonissen
Dan N. Tonissen
Senior Vice President, Chief Financial Officer, and Director

</TEXT>
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