SEC Comment Letter for GREG MANNING AUCTIONS INC (CIK 0000895516) — Jan 11, 2005
GREG MANNING AUCTIONS INC (CIK 0000895516)
Date: Jan. 11, 2005 · CIK: 0000895516 · Accession: 0000000000-05-001866
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<TYPE>LETTER
<SEQUENCE>1
<FILENAME>filename1.txt
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January 11, 2005
Mail Stop 0409
VIA U.S. MAIL and FAX (973) 882-2981
Mr. Larry Crawford
Chief Financial Officer
Greg Manning Auctions, Inc.
775 Passaic Avenue West
Caldwell, NJ 07006
Re: Greg Manning Auctions, Inc.
Form 10-K for the year ended June 30, 2004
File No. 1-11988
Dear Mr. Crawford:
We have reviewed your November 22, 2004 response letter and
have the following additional comment.
Form 10-K filed September 10, 2004
Notes to Consolidated Financial Statements, page 37
(1) Description of Business and Summary of Significant Accounting
Policies
Inventories, page 39
We noted your response to comment 6. What factors determine
whether
a certain inventory item falls under the specific identification
method versus using an estimate to write-down inventory based on a
percentage of the inventory aging by category? Also, clarify for
us
whether items are subject to a write-down under both
methodologies.
Please include support for your accounting in using both
methodologies.
As appropriate, please respond to this comment within 10
business days or tell us when you will provide us with a response.
Please file your response on EDGAR. Please understand that we may
have additional comments after reviewing your response to our
comment.
You may contact Monica Brame, Staff Accountant, at (202)
824-
5492 or me at (202) 942-1852 with any other questions.
Sincerely,
Donna Di Silvio
Accounting Branch Chief
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Greg Manning Auctions, Inc.
January 11, 2005
Page 1
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