SEC Comment Letter for AVENUE ENTERTAINMENT GROUP — Jun 21, 2005
AVENUE ENTERTAINMENT GROUP INC /DE/ (CIK 0001023298)
Date: June 21, 2005 · CIK: 0001023298 · Accession: 0000000000-05-031420
AI Filing Summary & Sentiment
File numbers found in text: 001-12885
Letter
June 22, 2005 Via US Mail and Facsimile Mr. Cary Brokaw Chief Executive and Financial Officer Avenue Entertainment Group, Inc. 10202 West Washington Blvd., Lean 119 Culver City, CA 90232
Re: Avenue Entertainment Group, Inc. Form 10-K for the year ended December 31, 2004 Commission File Number: 001-12885
Dear Mr. Brokaw:
We have reviewed your June 8, 2005 respons e letter and have the following comments. Where expanded or revised disc losure is requested, you may co mply with these comments in future filings. If you disagree, we will consid er your explanation as to why our comments are inapplicable or a revision is unnecessary. We also ask you to provide us with supplemental information so we may better understand your disclosu re. Please be as detailed as necessary in your explanation. We look forward to working with you in these resp ects and welcome any questions you may have about any aspects of our review.
* * * * * * * * * * * 1. Refer to our previous comment 5. We assume, from your respons e, that Columbia Pictures granted permission to use this facility directly to the company without receiving any form of consideration. If our assumption is not co rrect, please explain how, why and from whom, you received permission to use this facility.
* * * * * * * * * * *
As appropriate, please amend your filing and respond to these comments within 10 business days or tell us when you will provide us with a response. You may wish to provide us with marked copies of the amendment to expedite our review. Please furn ish a cover letter with your amendment that keys your responses to our comments and pr ovides any requested supplemental 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.
Mr. Cary Brokaw Avenue Entertainm ent Group, Inc. June 22, 2005 Page 2
We urge all persons who are responsible fo r the accuracy and adequ acy of the disclosure in the filing reviewed by the staff to be certain that they have provided all information investors require for an informed decision. Since the comp any and its management are in possession of all facts relating to a company’s disclosure, they are responsible for the acc uracy and adequacy of the disclosures they have made.
In connection with responding to our comme nts, please provide, in writing, a statement from the company acknowledging that:
the company is responsible for the adequacy and accuracy of the disclo sure in the filing;
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
the company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federa l securities laws of the United States.
In addition, please be advi sed that the Division of Enforcement has access to all information you provide to the staff of the Divisi on of Corporation Finance in our review of your filing or in response to our comments on your filing.
You may contact Amy Geddes at 202- 551-3304 or Margery Reich at 202-551- 3347 if you have questions regarding comments on the financial stat ements and related matters. Please contact me at 202-551-3211 with any other questions.
S i n c e r e l y ,
David R. Humphrey B r a n c h C h i e f
Show Raw Text
June 22, 2005
Via US Mail and Facsimile
Mr. Cary Brokaw
Chief Executive and Financial Officer
Avenue Entertainment Group, Inc.
10202 West Washington Blvd., Lean 119
Culver City, CA 90232
Re: Avenue Entertainment Group, Inc.
Form 10-K for the year ended December 31, 2004
Commission File Number: 001-12885
Dear Mr. Brokaw:
We have reviewed your June 8, 2005 respons e letter and have the following comments.
Where expanded or revised disc losure is requested, you may co mply with these comments in
future filings. If you disagree, we will consid er your explanation as to why our comments are
inapplicable or a revision is unnecessary. We also ask you to provide us with supplemental
information so we may better understand your disclosu re. Please be as detailed as necessary in
your explanation. We look forward to working with you in these resp ects and welcome any
questions you may have about any aspects of our review.
* * * * * * * * * * *
1. Refer to our previous comment 5. We assume, from your respons e, that Columbia Pictures
granted permission to use this facility directly to the company without receiving any form of
consideration. If our assumption is not co rrect, please explain how, why and from whom,
you received permission to use this facility.
* * * * * * * * * * *
As appropriate, please amend your filing and respond to these comments within 10
business days or tell us when you will provide us with a response. You may wish to provide us
with marked copies of the amendment to expedite our review. Please furn ish a cover letter with
your amendment that keys your responses to our comments and pr ovides any requested
supplemental 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.
Mr. Cary Brokaw
Avenue Entertainm ent Group, Inc.
June 22, 2005
Page 2
We urge all persons who are responsible fo r the accuracy and adequ acy of the disclosure
in the filing reviewed by the staff to be certain that they have provided all information investors
require for an informed decision. Since the comp any and its management are in possession of all
facts relating to a company’s disclosure, they are responsible for the acc uracy and adequacy of
the disclosures they have made.
In connection with responding to our comme nts, please provide, in writing, a statement
from the company acknowledging that:
the company is responsible for the adequacy and accuracy of the disclo sure in the filing;
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
the company may not assert staff comments as a defense in any proceeding initiated by
the Commission or any person under the federa l securities laws of the United States.
In addition, please be advi sed that the Division of Enforcement has access to all
information you provide to the staff of the Divisi on of Corporation Finance in our review of your
filing or in response to our comments on your filing.
You may contact Amy Geddes at 202- 551-3304 or Margery Reich at 202-551-
3347 if you have questions regarding comments on the financial stat ements and related matters.
Please contact me at 202-551-3211 with any other questions.
S i n c e r e l y ,
David R. Humphrey
B r a n c h C h i e f