SEC Company Response from TARRANT APPAREL GROUP (CIK 0000944948) — Nov 29, 2005
TARRANT APPAREL GROUP (CIK 0000944948)
Date: Nov. 29, 2005 · CIK: 0000944948 · Accession: 0001170918-05-000900
AI Filing Summary & Sentiment
Referenced dates: November 22, 2005
Letter
RE: TARRANT APPAREL GROUP RESPONSES TO STAFF COMMENTS OF NOVEMBER 22, 2005 WITH RESPECT TO:
STUBBS ALDERTON & MARKILES, LLP LETTERHEAD
JOHN MCILVERY Partner Direct 818.444.4502 Voice Direct Fax 818.474.8602 E-Mail jmcilvery@biztechlaw.com
November 29, 2005
VIA EDGAR
Securities and Exchange Commission Division of Corporation Finance Mail Stop 3561 Washington, D.C. 20549
ITEM 4.01 FORM 8-K FILED NOVEMBER 22, 2005 FILE NO. 0-26006
Ladies and Gentlemen:
On behalf of Tarrant Apparel Group (the "COMPANY"), we hereby provide the following responses in reply to the Staff's comment letter, dated November 22, 2005 (the "COMMENT LETTER"). In addition, we have enclosed for filing a copy of the amendment on Form 8-K/A to the Company's Current Report on Form 8-K filed on November 22, 2005 (the "FORM 8-K/A").
The factual information provided herein relating to the Company has been made available to us by the Company. Paragraph numbering used for each supplemental response set forth below corresponds to the numbering used in the Comment Letter.
1. PLEASE REVISE TO STATE IF GRANT THORNTON RESIGNED OR IF THEY WERE DISMISSED. WE DO NOT BELIEVE THE STATEMENT THAT YOU REPLACED THEM SATISFIES THE REQUIREMENT OF ITEM 304(A)(1)(I) OF REGULATION S-K. ALSO PLEASE NOTE THAT THE ENGAGEMENT OF NEW AUDITORS IS AN EVENT SEPARATE FROM THE DISMISSAL OR RESIGNATION OF YOUR FORMER AUDITORS. PLEASE REVISE TO CLARIFY THAT THE DATE OF THE RESIGNATION/DISMISSAL EVENT WAS ALSO NOVEMBER 17, 2005, IF TRUE.
The Company has revised the disclosure in the Form 8-K/A to clarify that Grant Thornton was dismissed, and that such dismissal was also effective November 17, 2005.
In addition to the foregoing, attached to this response letter is a letter from the Company stating the Company's acknowledgement of the matters requested on Page 2 of the Comment Letter.
15821 Ventura Boulevard, Suite 525, Encino, California 91436 office > 818.444.4500 fax > 818.444.4520 www.biztechlaw.com <PAGE>
Securities and Exchange Commission November 29, 2005 Page 2
We hope the above has been responsive to the Staff's comments. If you have any questions or require any additional information or documents, please telephone me at (818) 444-4502.
Sincerely,
/s/ John J. McIlvery ---------------------- John J. McIlvery
cc: Barry Aved Corazon Reyes
<PAGE>
TARRANT APPAREL GROUP 3151 EAST WASHINGTON BOULEVARD LOS ANGELES, CALIFORNIA 90023
November 29, 2005
Securities and Exchange Commission Division of Corporation Finance Washington, D.C. 20549 Mail Stop 3561
RE: TARRANT APPAREL GROUP RESPONSES TO STAFF COMMENTS OF NOVEMBER 22, 2005 WITH RESPECT TO:
ITEM 4.01 FORM 8-K FILED NOVEMBER 22, 2005 FILE NO. 0-26006
Ladies and Gentlemen:
This letter is provided by Tarrant Apparel Group (the "Company") in response to the comment letter from the Staff of the Securities Exchange Commission dated November 22, 2005 with respect the filing listed above. The Company acknowledges that:
o the Company is responsible for the adequacy and accuracy of the disclosure in the filing;
o staff comments or changes to the 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
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.
Very truly yours,
TARRANT APPAREL GROUP
Show Raw Text
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<TEXT>
STUBBS ALDERTON & MARKILES, LLP LETTERHEAD
JOHN MCILVERY
Partner
Direct 818.444.4502
Voice
Direct Fax 818.474.8602
E-Mail jmcilvery@biztechlaw.com
November 29, 2005
VIA EDGAR
Securities and Exchange Commission
Division of Corporation Finance
Mail Stop 3561
Washington, D.C. 20549
RE: TARRANT APPAREL GROUP
RESPONSES TO STAFF COMMENTS OF NOVEMBER 22, 2005 WITH RESPECT TO:
ITEM 4.01 FORM 8-K FILED NOVEMBER 22, 2005
FILE NO. 0-26006
Ladies and Gentlemen:
On behalf of Tarrant Apparel Group (the "COMPANY"), we hereby provide
the following responses in reply to the Staff's comment letter, dated November
22, 2005 (the "COMMENT LETTER"). In addition, we have enclosed for filing a copy
of the amendment on Form 8-K/A to the Company's Current Report on Form 8-K filed
on November 22, 2005 (the "FORM 8-K/A").
The factual information provided herein relating to the Company has
been made available to us by the Company. Paragraph numbering used for each
supplemental response set forth below corresponds to the numbering used in the
Comment Letter.
1. PLEASE REVISE TO STATE IF GRANT THORNTON RESIGNED OR IF THEY WERE
DISMISSED. WE DO NOT BELIEVE THE STATEMENT THAT YOU REPLACED THEM
SATISFIES THE REQUIREMENT OF ITEM 304(A)(1)(I) OF REGULATION S-K. ALSO
PLEASE NOTE THAT THE ENGAGEMENT OF NEW AUDITORS IS AN EVENT SEPARATE
FROM THE DISMISSAL OR RESIGNATION OF YOUR FORMER AUDITORS. PLEASE
REVISE TO CLARIFY THAT THE DATE OF THE RESIGNATION/DISMISSAL EVENT WAS
ALSO NOVEMBER 17, 2005, IF TRUE.
The Company has revised the disclosure in the Form 8-K/A to clarify
that Grant Thornton was dismissed, and that such dismissal was also effective
November 17, 2005.
In addition to the foregoing, attached to this response letter is a
letter from the Company stating the Company's acknowledgement of the matters
requested on Page 2 of the Comment Letter.
15821 Ventura Boulevard, Suite 525, Encino, California 91436
office > 818.444.4500 fax > 818.444.4520 www.biztechlaw.com
<PAGE>
Securities and Exchange Commission
November 29, 2005
Page 2
We hope the above has been responsive to the Staff's comments. If you
have any questions or require any additional information or documents, please
telephone me at (818) 444-4502.
Sincerely,
/s/ John J. McIlvery
----------------------
John J. McIlvery
cc: Barry Aved
Corazon Reyes
<PAGE>
TARRANT APPAREL GROUP
3151 EAST WASHINGTON BOULEVARD
LOS ANGELES, CALIFORNIA 90023
November 29, 2005
Securities and Exchange Commission
Division of Corporation Finance
Washington, D.C. 20549
Mail Stop 3561
RE: TARRANT APPAREL GROUP
RESPONSES TO STAFF COMMENTS OF NOVEMBER 22, 2005 WITH RESPECT TO:
ITEM 4.01 FORM 8-K FILED NOVEMBER 22, 2005
FILE NO. 0-26006
Ladies and Gentlemen:
This letter is provided by Tarrant Apparel Group (the "Company") in
response to the comment letter from the Staff of the Securities Exchange
Commission dated November 22, 2005 with respect the filing listed above. The
Company acknowledges that:
o the Company is responsible for the adequacy and accuracy of
the disclosure in the filing;
o staff comments or changes to the 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
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.
Very truly yours,
TARRANT APPAREL GROUP
By: /S/ BARRY AVED
-------------------------
Barry Aved
Chief Executive Officer
</TEXT>
</DOCUMENT>