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SEC Comment Letter for TRADESTATION GROUP INC (CIK 0001111559) — Aug 17, 2005

TRADESTATION GROUP INC (CIK 0001111559)
Date: Aug. 17, 2005 · CIK: 0001111559 · Accession: 0000000000-05-042618

AI Filing Summary & Sentiment

File numbers found in text: 000-31049

Date
August 18, 2005
Author
Paul Cline
Form
UPLOAD
Company
TRADESTATION GROUP INC (CIK 0001111559)

Letter

Mail Stop 4561 August 18, 2005 David H. Fleischman Chief Financial Officer TradeStation Group, Inc. 8050 S.W. 10th Street, Suite 4000 Plantation, Florida 33324

RE: TradeStation Group, Inc. Form 10-K for Fiscal Year Ended December 31, 2004 Filed March 8, 2005 File No. 000-31049

Dear Mr. Fleischman,

We have reviewed the above referenced filing, limiting our review to the issue addressed in our comment. Please provide us with the requested information so we may better understand your disclosure. After reviewing this information, we may raise additional comments. Please provide disclosures in your future filings that clarify the issue addressed in our comment.

Please understand that the purpose of our review process is to assist you in your compliance with the applicable disclosure requirements and to enhance the overall disclosure in your filing. We look forward to working with you in these respects. We welcome any questions you may have about our comment or any other aspect of our review. Feel free to call us at the telephone numbers listed at the end of this letter.

Item 9A - Controls and Procedures, page 47

1. Please tell us and revise in future filings, if your disclosure controls and procedures are effective at the "reasonable assurance" level. Refer to the conclusions regarding effectiveness of disclosure controls and procedures in Release No. 33-8238: Management`s Reports on Internal Control over Financial Reporting and Certification of Disclosure in Exchange Act Periodic Reports effective August 14, 2003.

Please respond to this comment within 10 business days or tell us when you will provide us with a response. Your letter should key your response to our comment and provide any requested information. Please file your letter on EDGAR. Please understand that we may have additional comments after reviewing your response to our comment.

We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes all information required under the Securities Exchange Act of 1934 and that they have provided all information investors require for an informed decision. Since the company and its management are in possession of all facts relating to a company`s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made.

In connection with responding to our comment, please provide, in writing, a statement from the company acknowledging that:

* the company is responsible for the adequacy and accuracy of the disclosure 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 federal securities laws of the United States.

In addition, please be advised that the Division of Enforcement has access to all information you provide to the staff of the Division of Corporation Finance in our review of your filing or in response to our comment on your filing.

You may contact Michael Volley, Staff Accountant, at (202) 551- 3437 or me at (202) 551-3851 if you have questions regarding our comment.

Sincerely,
Paul Cline
Senior Accountant

Show Raw Text
<DOCUMENT>
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<FILENAME>filename1.txt
<TEXT>

Mail Stop 4561

August 18, 2005

David H. Fleischman
Chief Financial Officer
TradeStation Group, Inc.
8050 S.W. 10th Street, Suite 4000
Plantation, Florida 33324

RE:	TradeStation Group, Inc.
Form 10-K for Fiscal Year Ended December 31, 2004
Filed March 8, 2005
File No. 000-31049

Dear Mr. Fleischman,

	We have reviewed the above referenced filing, limiting our
review to the issue addressed in our comment.  Please provide us
with
the requested information so we may better understand your
disclosure.  After reviewing this information, we may raise
additional comments.  Please provide disclosures in your future
filings that clarify the issue addressed in our comment.

	Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comment or any other aspect
of
our review.  Feel free to call us at the telephone numbers listed
at
the end of this letter.

Item 9A - Controls and Procedures, page 47

1. Please tell us and revise in future filings, if your disclosure
controls and procedures are effective at the "reasonable
assurance"
level.  Refer to the conclusions regarding effectiveness of
disclosure controls and procedures in Release No. 33-8238:
Management`s Reports on Internal Control over Financial Reporting
and
Certification of Disclosure in Exchange Act Periodic Reports
effective August 14, 2003.

	Please respond to this comment within 10 business days or
tell
us when you will provide us with a response.  Your letter should
key
your response to our comment and provide any requested
information.
Please file your letter on EDGAR.  Please understand that we may
have
additional comments after reviewing your response to our comment.

	We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing to be certain that the
filing includes all information required under the Securities
Exchange Act of 1934 and that they have provided all information
investors require for an informed decision.  Since the company and
its management are in possession of all facts relating to a
company`s
disclosure, they are responsible for the accuracy and adequacy of
the
disclosures they have made.

	In connection with responding to our comment, please provide,
in
writing, a statement from the company acknowledging that:

* the company is responsible for the adequacy and accuracy of the
disclosure 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
federal securities laws of the United States.

	In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filing or in
response to our comment on your filing.

	You may contact Michael Volley, Staff Accountant, at (202)
551-
3437 or me at (202) 551-3851 if you have questions regarding our
comment.

Sincerely,

Paul Cline
Senior Accountant

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David H. Fleischman
TradeStation Group, Inc.
August 18, 2005
Page 2

</TEXT>
</DOCUMENT>