COLLECTORS
UNIVERSE, INC.
1921 E.
Alton Avenue,
Santa
Ana, California 92705
(949)
567-1234
March 9,
2005
VIA
EDGARLINK AND FACSIMILE (202-942-9635)
Securities
and Exchange Commission
450 Fifth
Street, N.W.
Washington,
D.C. 20549-0404
Attn: Kathleen
A. Collins, Branch Chief
Division
of Corporation Finance
Mail Stop
04-09
Re: Collectors
Universe, Inc.
File No.
0-27887
Form 10-K
for the Year ended June 30, 2004
Form 10-K/A -
Amendment No. 1 filed January 19, 2005
Ladies
and Gentlemen:
Set forth
in the attachment to this letter is the response of Collectors Universe, Inc.
(the “Company”) to the comment of the Staff of the Securities and Exchange
Commission (the “Staff”), contained in its letter dated February 28, 2005 (the
“Comment Letter”), relating to the Amendment No. 1 on Form 10-K/A (“Amendment
No. 1”)
to the Company’s Annual Report on Form 10-K for the year ended June 30, 2004. As
noted above Amendment No. 1 was
filed with the Commission on January 19, 2005.
Additionally,
as requested, the Company acknowledges that:
| · |
The
Company is responsible for the adequacy and accuracy of the disclosure in
Amendment No.1; |
| · |
Staff
comments or changes in disclosure in response to Staff comments do not
foreclose the Commission from taking any action with respect to Amendment
No.1; and |
| · |
The
Company may not assert Staff comments as a defense in any proceeding that
might be initiated by the Commission or any person under the federal
securities laws of the United States. |
If you
have any questions or would like to discuss the attached response with us,
please do not hesitate to call me at (949) 567-1375.
Sincerely
/s/MICHAEL
J. LEWIS
Michael
J. Lewis, Chief Financial Officer
cc:
Lori Smith
Ben A.
Frydman, Esq.
|
Re: |
Collectors
Universe, Inc. |
File No.
0-27887
RESPONSE
OF COLLECTORS UNIVERSE, INC. TO THE LETTER OF COMMENT, DATED AS OF FEBRUARY
28, 2005
FROM THE
STAFF OF THE SECURITIES AND EXCHANGE COMMISSION RELATING TO AMENDMENT NO. 1 ON
FORM 10-K/A
TO THE
COMPANY’S ANNUAL REPORT ON FORM 10-K FOR THE FISCAL YEAR ENDED JUNE 30, 2004
Comment
No. Comment
and Company Response
1. Report
of Independent Registered Public Accounting Firm, Page 16.
It
appears that the second paragraph of the audit report has been amended to
include some of the suggested language from AU Section 9408.18. The suggested
modification from AU 9508.18 also includes the following language “The Company
is not required to have, nor were we engaged to perform, an audit of its control
over financing reporting.” Either revise to include this additional sentence or
have your auditors tell us why they believe revision is not necessary. We may
have further comment upon review of the response.
Response:
Deloitte & Touche LLP, the Independent Registered Public Accounting Firm
that issued the audit report, has informed us that:
The
second paragraph of the firm’s audit report on the Company’s financial
statements included in Amendment No. 1 was modified, in accordance with its
policies at the
date of reissuance, to inform readers that the scope of the financial statement
audit did not include consideration of the Company’s internal control over
financial reporting for the purpose of expressing an opinion
thereon.
Auditing
Interpretation No. 18 (AU 9508.18), ”Reference to PCAOB Standards in an Audit
Report on a Nonissuer” is, by definition, not applicable to the Company’s
financial statements as the Company is an issuer.
Additionally,
this interpretation states, ”The following Auditing Interpretation No. 18
reflects generally accepted auditing standards issued or modified by the AICPA
after April 16, 2003. As such, the following Auditing Interpretation No. 8
is not part of the standards adopted or established by the Public Company
Accounting Oversight Board.”
As the
audit was conducted in accordance with the standards of the Public Company
Accounting Oversight Board, the additional sentence from AU 9508.18 is not
required to be included in the firm’s report.