-----BEGIN PRIVACY-ENHANCED MESSAGE----- Proc-Type: 2001,MIC-CLEAR Originator-Name: webmaster@www.sec.gov Originator-Key-Asymmetric: MFgwCgYEVQgBAQICAf8DSgAwRwJAW2sNKK9AVtBzYZmr6aGjlWyK3XmZv3dTINen TWSM7vrzLADbmYQaionwg5sDW3P6oaM5D3tdezXMm7z1T+B+twIDAQAB MIC-Info: RSA-MD5,RSA, DsGDTdhYEyavgu6W5jJ+g2CldSLh4Er2iLDJJKkaVu/1JqfbOxe4F5GP0T4ycgyw 2pedyaA47oDqBRi2FdyGZg== 0000000000-05-011666.txt : 20060525 0000000000-05-011666.hdr.sgml : 20060525 20050311145621 ACCESSION NUMBER: 0000000000-05-011666 CONFORMED SUBMISSION TYPE: UPLOAD PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20050311 FILED FOR: COMPANY DATA: COMPANY CONFORMED NAME: EDUCATIONAL DEVELOPMENT CORP CENTRAL INDEX KEY: 0000031667 STANDARD INDUSTRIAL CLASSIFICATION: WHOLESALE-MISCELLANEOUS NONDURABLE GOODS [5190] IRS NUMBER: 730750007 STATE OF INCORPORATION: DE FISCAL YEAR END: 0228 FILING VALUES: FORM TYPE: UPLOAD BUSINESS ADDRESS: STREET 1: 10302 E 55TH PL #B CITY: TULSA STATE: OK ZIP: 74146 BUSINESS PHONE: 9186224522 MAIL ADDRESS: STREET 1: PO BOX 470663 CITY: TULSA STATE: OK ZIP: 741460663 FORMER COMPANY: FORMER CONFORMED NAME: TUTOR TAPES INTERNATIONAL CORP DATE OF NAME CHANGE: 19701030 FORMER COMPANY: FORMER CONFORMED NAME: INTERNATIONAL TEACHING TAPES INC DATE OF NAME CHANGE: 19701030 PUBLIC REFERENCE ACCESSION NUMBER: 0000950134-05-003851 LETTER 1 filename1.txt Mail Stop 0308 March 9, 2005 Randall W. White President and Chief Executive Officer Educational Development Corporation 10302 East 55th Place Tulsa, OK 74146-6515 RE: Educational Development Corporation Item 4.01 Form 8-K filed February 28, 2005 File No. 0-4957 Dear Mr. White: We have reviewed the above referenced filing and have the following comments. We welcome any questions you may have about our comments. Feel free to contact us at the telephone numbers listed at the end of this letter. 1. You state that there were no disagreements with your former accountants through November 30, 2004. Please revise to state that there were no disagreements through February 22, 2005, if true. See Item 304(a)(1)(iv) of Regulation S-K. The disclosure with respect to consultations with your new auditor should also cover the interim period preceding their engagement. Please revise accordingly. 2. Please revise the first paragraph to state you dismissed Deloitte & Touche, if true. We do not believe the statement that you decided not to re-engage them satisfies the requirements of Item 304(a)(1)(i) of Regulation S-K. Please revise or advise. We urge all persons who are responsible for the accuracy and adequacy 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 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. Educational Development Corporation March 9, 2005 Page 2 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 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 this action 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 connection with our review of your filing or in response to our comments on your filing. Please file your amendment within five business days from the date of this letter. The amendment should include an updated letter from your former accountants. The supplemental information we requested should be filed on EDGAR as correspondence. Any questions regarding the above should be directed to me at (202) 942-1809, or in my absence, to Robert Benton at (202) 942-1811. Sincerely, Robert Burnett Staff Accountant ?? ?? ?? ?? -----END PRIVACY-ENHANCED MESSAGE-----