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SEC Comment Letter for Luvu Brands, Inc. (LUVU) (CIK 0001374567) (LUVU) — Mar 8, 2013

Luvu Brands, Inc. (LUVU) (CIK 0001374567)
Date: March 8, 2013 · CIK: 0001374567 · Accession: 0000000000-13-012789

AI Filing Summary & Sentiment

File numbers found in text: 000-53314

Referenced dates: February 20, 2013

Date
March 8, 2013
Author
/s/ Terence O ’Brien
Form
UPLOAD
Company
Luvu Brands, Inc. (LUVU) (CIK 0001374567)

Letter

March 8, 2013 Via E -mail Mr. Louis S. Friedman Chief Executive Officer Liberator, Inc. 2745 Bankers Industrial Drive Atlanta, Georgia 30360

RE: Liberator, Inc. Form 10-K for the Fis cal Year Ended June 30 , 2012 Filed October 11 , 2012 File No . 000-53314

Dear Mr. Friedman :

We have reviewed your response letter dated February 20, 2013, and have the following additional comment. If you disagree, we will consider your explanation as to why our comment is inapplicable.

Please respond to this letter within ten business days by providing the requested information, or by advising us when you will provide the requested response. If you do not believe our comment applies to your facts and circumstances please tell us why in your response.

After reviewing the information you provide in response to this comment , we may have additional comments.

Form 10 -Q for the Fiscal Quarter En ded December 31, 2012

Results of Operations, page 22

1. You present a tabular presentation of your net sales by product type but didn’t provide a corresponding discussion of the underlying reasons for the change in sales period over period by product type. Your current discussion quantifies percentage changes period over period but provides little insight into underlying reasons driving such changes. In future filings please provide an analysis that not only quantifies the changes period over period, but cl early provides a robust discussion of the underlying reasons driving such changes. Refer to Section 501.05 and 04 of the Financial Reporting Codification for Guidance.

Mr. Friedman Liberator, Inc. March 8 , 2013 Page 2

You may contact Tracey McKoy, Staff Accountant, at (202) 551 -3772 or, in her abs ence, the undersigned Accounting Branch Chief at (202) 551 -3355 if you have questions regarding comments on the financial statements and related matters.

Sincerely,
/s/ Terence O ’Brien

Show Raw Text
March 8, 2013

Via E -mail
Mr. Louis S. Friedman
Chief Executive  Officer
Liberator, Inc.
2745 Bankers Industrial Drive
Atlanta, Georgia 30360

 RE: Liberator, Inc.
  Form 10-K for the Fis cal Year Ended June 30 , 2012
  Filed October 11 , 2012
  File No . 000-53314

Dear Mr. Friedman :

We have reviewed your response letter dated February 20, 2013,  and have the following
additional comment.  If you disagree, we will consider your explanation as to why our comment
is inapplicable.

Please respond to this letter within ten business days by providing the requested
information, or by advising us when you will provide the requested response.   If you do not
believe our comment applies to your facts and circumstances please tell us why in your response.

After reviewing the information you provide in response to this comment , we may have
additional comments.

Form 10 -Q for the Fiscal Quarter En ded December 31, 2012

Results of Operations, page 22

1. You present a tabular presentation of your net sales by product type but didn’t provide a
corresponding discussion of the underlying reasons for the change in sales period over
period by product type. Your current discussion quantifies percentage changes period
over period but provides little insight into underlying reasons driving such changes.  In
future filings please provide an analysis that not only quantifies the changes period over
period, but cl early provides a robust discussion of the underlying reasons driving such
changes.  Refer to Section 501.05 and 04 of the Financial Reporting Codification for
Guidance.

Mr. Friedman
Liberator, Inc.
March 8 , 2013
Page 2

 You may contact Tracey McKoy, Staff Accountant, at (202) 551 -3772 or, in her abs ence,
the undersigned Accounting Branch Chief at (202) 551 -3355 if you have questions regarding
comments on the financial statements and related matters.

Sincerely,

        /s/ Terence O ’Brien

        Terence O’Brien
        Accounting Branch Chief