SEC Company Response from SUPERIOR GALLERIES INC (CIK 0001091539) — Mar 21, 2005

SUPERIOR GALLERIES INC (CIK 0001091539)
Date: March 21, 2005 · CIK: 0001091539 · Accession: 0001019687-05-000753

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AI Filing Summary & Sentiment

File numbers found in text: 333-119253

Date

March 21, 2005

Author

Not clearly detected

Form

CORRESP

Company

SUPERIOR GALLERIES INC (CIK 0001091539)

Letter

SUPERIOR GALLERIES, INC. 9478 WEST OLYMPIC BOULEVARD BEVERLY HILLS, CA 90212 March 21, 2005 Mr. Matthew Benson Securities & Exchange Commission 450 5th Street, N.W. Washington, D.C. 20549

RE: SUPERIOR GALLERIES, INC. ACCELERATION OF THE EFFECTIVE DATE REGISTRATION STATEMENT ON FORM SB-2 FILE NO. 333-119253

Dear Mr. Benson:

We hereby request, pursuant to Rule 461(a) of Regulation C, that the above-referenced Registration Statement be declared effective at 10:00 a.m. Eastern Time on March 22, 2005 or as soon as practicable thereafter. The Company confirms that it is aware of its obligations under the Securities Act of 1933 and acknowledges that:

o the Company is responsible for the adequacy and accuracy of the disclosure in its filings with the Securities and Exchange Commission (the "Commission");

o staff comments or changes to 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 staff comments and the declaration of effectiveness 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,
SUPERIOR GALLERIES, INC.

Show Raw Text

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<PAGE>

                            SUPERIOR GALLERIES, INC.
                           9478 WEST OLYMPIC BOULEVARD
                             BEVERLY HILLS, CA 90212

                                 March 21, 2005

Mr. Matthew Benson
Securities & Exchange Commission
450 5th Street, N.W.
Washington, D.C. 20549

RE:      SUPERIOR GALLERIES, INC.
         ACCELERATION OF THE EFFECTIVE DATE
         REGISTRATION STATEMENT ON FORM SB-2
         FILE NO. 333-119253

Dear Mr. Benson:

         We hereby request, pursuant to Rule 461(a) of Regulation C, that the
above-referenced Registration Statement be declared effective at 10:00 a.m.
Eastern Time on March 22, 2005 or as soon as practicable thereafter. The Company
confirms that it is aware of its obligations under the Securities Act of 1933
and acknowledges that:

         o        the Company is responsible for the adequacy and accuracy of
                  the disclosure in its filings with the Securities and Exchange
                  Commission (the "Commission");

         o        staff comments or changes to 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 staff comments and the declaration
                  of effectiveness 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,

                                        SUPERIOR GALLERIES, INC.

                                        By: /s/ Paul Biberkraut
                                        -------------------------------------
                                        Paul Biberkraut, Chief Financial Officer

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