-----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, F4ymocGdSYu2J9Wm4ELUedzApvccALmIKu1JS0Tk5TuqheBHwCWaedvMqY5cHeB/ CtWQp41lV/KBnm7nnPPV4w== 0000899078-04-000804.txt : 20051118 0000899078-04-000804.hdr.sgml : 20051118 20041215170520 ACCESSION NUMBER: 0000899078-04-000804 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20041215 FILER: COMPANY DATA: COMPANY CONFORMED NAME: EZCORP INC CENTRAL INDEX KEY: 0000876523 STANDARD INDUSTRIAL CLASSIFICATION: RETAIL-MISCELLANEOUS RETAIL [5900] IRS NUMBER: 742540145 STATE OF INCORPORATION: DE FISCAL YEAR END: 0930 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 1901 CAPITAL PKWY CITY: AUSTIN STATE: TX ZIP: 78746 BUSINESS PHONE: 5123143400 MAIL ADDRESS: STREET 1: 1901 CAPITAL PKWY CITY: AUSTIN STATE: TX ZIP: 78746 CORRESP 1 filename1.txt December 15, 2004 Securities and Exchange Commission Attn: Mr. Robert Burnett Mail Stop 3-8 Washington, D.C. 20549 Dear Mr. Burnett: I received your letter dated November 12, 2004 regarding Item 4.01 of EZCORP, Inc.'s Form 8-K filed October 12, 2004. In bold italics below are the comments in your letter, and in plain text is our response. I assume that our response will be held in confidence, subject only to disclosure pursuant to proper requests under the Freedom of Information Act ("FOIA"). I assume that any disclosure by the Staff of the information in this letter will comply with those procedures and request, as a courtesy, that you inform me if you become aware of any FOIA request regarding this response. Staff Comments: 1. We believe that the facts indicated in your filing represents a future dismissal of Ernst & Young. You will need to file an amendment to this Form 8-K when Ernst & Young is no longer serving in any capacity as your principal accountant. The amended Form 8-K should disclose this date and state that there are still no disagreements, if true. The amendment should also include an updated letter from Ernst & Young indicating whether or not they agree with the disclosures in the amendment. 2. We suggest the amendment indicate you dismissed Ernst & Young rather than saying they were terminated. "Dismissed" is the term specified in Rule 3-04 of Regulation S-X. Response: Ernst & Young's work as our principal accountant is now complete, and we have notified them of their dismissal as our principal accountant. On December 15, 2004, we filed the requested amendment to our Form 8-K, addressing the issues raised in your comments above. We also acknowledge that: o the Company is responsible for the adequacy and accuracy of the disclosures in the filing; o 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 o 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. Sincerely, /s/ Dan N. Tonissen Dan N. Tonissen Senior Vice President, Chief Financial Officer, and Director -----END PRIVACY-ENHANCED MESSAGE-----