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SEC Comment Letter for ELECTRONIC MEDIA CENTRAL CORP (CIK 0001133901) — Oct 27, 2005

ELECTRONIC MEDIA CENTRAL CORP (CIK 0001133901)
Date: Oct. 27, 2005 · CIK: 0001133901 · Accession: 0000000000-05-054697

AI Filing Summary & Sentiment

File numbers found in text: 000-32345

Date
October 27, 2005
Author
Jorge Bonilla
Form
UPLOAD
Company
ELECTRONIC MEDIA CENTRAL CORP (CIK 0001133901)

Letter

October 27, 2005 VIA USMAIL and FAX (775) 264-8821 Mr. George Morris Chief Executive Officer Electronic Media Central Corporation 413 Avenue G, #1 Redondo Beach, CA 90277

Re: Electronic Media Central Corporation Form 10-KSB for the year ended 3/31/2005 Filed on 6/30/2005 Form 10-QSB for the period ended 6/30/2005 Filed on 8/15/2005 File No. 000-32345

Dear Mr. George Morris:

We have reviewed your above referenced filings and have the following comments. We have limited our review to only your financial statements and related disclosures and will make no further review of your documents. As such, all persons who are responsible for the adequacy and accuracy of the disclosures are urged to be certain that they have included all information required pursuant to the Securities Exchange Act of 1934.

In our comments, we may ask you to provide us with information so we may better understand your disclosures. Please be as detailed as necessary in your explanation. After reviewing this information, we may or may not raise additional comments.

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 disclosures in your filings. We look forward to working with you in these respects. We welcome any questions you may have about our comments or on any other aspect of our review. Feel free to call us at the telephone numbers listed at the end of this letter.

FORM 10-KSB FOR THE YEAR ENDED MARCH 31, 2005

Financial Statements and Notes

Report of Independent Registered Public Accounting Firm, page 10

1. You present financial statements for the years ended March 31, 2005 and March 31, 2004. However, your audit opinion references only March 31, 2005. Tell us how you considered the guidance in Item 2-02 of Regulation S-X. Note 2 - Summary of Significant Accounting Policies & Realization of Assets

Accounts Payable & Accrued Expenses, page 16

2. On page 8, you mention litigation with Banco PanAmericano. Tell us the nature of this litigation and how you considered SFAS 5 in determining whether or not to record a loss contingency related to this litigation.

FORM 10-QSB FOR THE PERIOD ENDED JUNE 30, 2005

Statements of Cash Flows, page 6

3. Please explain to us in sufficient details the reasons for the significant decrease in Accounts receivable and Accounts payable & accrued liabilities from the balance as of March 31, 2005 to the balance as of June 30, 2005. Please quantify the factors that caused the decrease.

* * * *

As appropriate, please respond to these comments within 10 business days or tell us when you will provide us with a response. Please file your responses on EDGAR. Please understand that we may have additional comments after reviewing your responses to our comments.

We urge all persons who are responsible for the accuracy and adequacy of the disclosures in the filings reviewed by the staff to be certain 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 disclosures, they are responsible for the accuracy and adequacy of the disclosures they have made.

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

* the company is responsible for the adequacy and accuracy of the disclosures in the filings;

* staff comments or changes to disclosures in response to staff comments do not foreclose the Commission from taking any action with respect to the filings; 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 filings or in response to our comments on your filings.

You may contact Wilson K. Lee, at (202) 551-3468 or me at (202) 551-3414 if you have questions.

Sincerely,
Jorge Bonilla
Senior Staff Accountant
??

Show Raw Text
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Mail Stop 4561

      October 27, 2005

      VIA USMAIL and FAX (775) 264-8821

Mr. George Morris
Chief Executive Officer
Electronic Media Central Corporation
413 Avenue G, #1
Redondo Beach, CA 90277

      Re:	Electronic Media Central Corporation
		Form 10-KSB for the year ended 3/31/2005
      Filed on 6/30/2005
      Form 10-QSB for the period ended 6/30/2005
      Filed on 8/15/2005
      File No. 000-32345

Dear Mr. George Morris:

      We have reviewed your above referenced filings and have the
following comments.  We have limited our review to only your
financial statements and related disclosures and will make no
further
review of your documents.  As such, all persons who are
responsible
for the adequacy and accuracy of the disclosures are urged to be
certain that they have included all information required pursuant
to
the Securities Exchange Act of 1934.

      In our comments, we may ask you to provide us with
information
so we may better understand your disclosures.  Please be as
detailed
as necessary in your explanation.  After reviewing this
information,
we may or may not raise additional comments.

	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 disclosures in your
filings.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.

FORM 10-KSB FOR THE YEAR ENDED MARCH 31, 2005

Financial Statements and Notes

Report of Independent Registered Public Accounting Firm, page 10

1. You present financial statements for the years ended March 31,
2005 and March 31, 2004.   However, your audit opinion references
only March 31, 2005.   Tell us how you considered the guidance in
Item 2-02 of Regulation S-X.
Note 2 - Summary of Significant Accounting Policies & Realization
of
Assets

Accounts Payable & Accrued Expenses, page 16

2. On page 8, you mention litigation with Banco PanAmericano.
Tell
us the nature of this litigation and how you considered SFAS 5 in
determining whether or not to record a loss contingency related to
this litigation.

FORM 10-QSB FOR THE PERIOD ENDED JUNE 30, 2005

Statements of Cash Flows, page 6

3. Please explain to us in sufficient details the reasons for the
significant decrease in Accounts receivable and Accounts payable &
accrued liabilities from the balance as of March 31, 2005 to the
balance as of June 30, 2005. Please quantify the factors that
caused
the decrease.

*    *    *    *

      As appropriate, please respond to these comments within 10
business days or tell us when you will provide us with a response.
Please file your responses on EDGAR.  Please understand that we
may
have additional comments after reviewing your responses to our
comments.

	We urge all persons who are responsible for the accuracy and
adequacy of the disclosures in the filings reviewed by the staff
to
be certain 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 disclosures,
they
are responsible for the accuracy and adequacy of the disclosures
they
have made.

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

* the company is responsible for the adequacy and accuracy of the
disclosures in the filings;

* staff comments or changes to disclosures in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filings; 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 filings or
in
response to our comments on your filings.

      You may contact Wilson K. Lee, at (202) 551-3468 or me at
(202)
551-3414 if you have questions.

								Sincerely,

      Jorge Bonilla
      Senior Staff Accountant
??

??

??

??

George Morris
Electronic Media Central Corporation
October 27, 2005
Page 1

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