August 11, 2005
Ms. Linda Cvrkel
Branch Chief
U. S. Securities and Exchange Commission
Washington D.C. 20549
Re: Precision Auto Care, Inc.
Form 10-KSB for the fiscal year ended June 30, 2004
Form 10-Q for the quarter ended September 30, 2004, December 31, 2004 and March 31, 2005
Commission file #: 000-29478
Dear Ms. Cvrkel:
I am in receipt of your letter dated June 22, 2005. The following is our response to each of the comments in the order that they appeared in your letter.
1. Please file an amended Form 10-KSB in response to our previous comment 1.
Response:
An amended Form 10-KSB was filed on July 14, 2005.
Form 10-Q for the period ended December 31, 2004
2. We note from your response to comment 2 that your disclosure was revised for the quarter ended March 31, 2005 to explain why only $130,000 of revenue was recognized. However, we believe that the explanation included in your response is clearer than that included in your Form 10-QSB disclosure. Please include similar explanatory language in your disclosure in future filings.
Response:
Future filings will include similar explanatory language as recommended.
Sincerely,
/s/ Robert R. Falconi |
|
| |
Robert R. Falconi | |
President and Chief Operating Officer | |
