Re:
Infusion Brands International, Inc.
Form 10-K For the Fiscal Year Ended June 30, 2010
Dear Mr. Decker
On February 2, 2011, we submitted our responses to your letter dated January 19, 2011. In response to additional clarification requested by you, we are filing this supplement to our prior response with respect to your letter request.
Addendum to our response letter filed February 2, 2011:
SEC Comment 3 Addendum
We will allocate depreciation and amortization to cost of sales for any appropriate amounts in our future filings including our Form 10-KT transition report. We will also provide the applicable amounts of depreciation and amortization included in cost of sales by parenthetical disclosure in our statement of operations.
SEC Comment 5 Addendum
Noncontrolling Interest
In accordance with ASC 220-10-45-5, we will report in our financial statements the required components of comprehensive income and related disclosure requirements. In accordance with this standard, we will report amounts of comprehensive income attributable to our parent company interest and comprehensive income attributable to the noncontrolling interest. See Exhibit II (Revised) for financial statement presentation.
Sincerely,
/s/ Robert John DeCecco III
Robert John DeCecco III
President, Chief Executive Officer and Chief Financial Officer
Exhibit II – (Revised)
SEC Comment 5
INFUSION BRANDS INTERNATIONAL, INC. AND SUBSIDIARIES
| | | Total | | | Comprehensive Income | | | Accumulated Deficit | | | Accumulated Other Comprehensive Income | | | Preferred Stock | | | Additional Paid in Capital | | | Noncontrolling Interest | |
| Balance June 30, 20XX | | $ | - | | | $ | - | | | $ | - | | | $ | - | | | $ | - | | | $ | - | | | $ | - | |
Comprehensive Income | | | | | | | | | | | | | | | | | | | | | | | | | | | | |
| Net Income (loss) | | | - | | | | - | | | | - | | | | - | | | | - | | | | - | | | | - | |
| Other Comprehensive income (loss): | | | | | | | | | | | | | | | | | | | | | | | | | | | | |
| Unrealized gains (losses) on available for sale investments | | | - | | | | - | | | | - | | | | - | | | | - | | | | - | | | | - | |
| Other comprehensive income (loss) | | | - | | | | - | | | | - | | | | - | | | | - | | | | - | | | | - | |
| Comprehensive income | | | - | | | $ | - | | | | | | | | | | | | | | | | | | | | | |
| Balance December 31, 20XX | | $ | - | | | | - | | | $ | - | | | $ | - | | | $ | - | | | $ | - | | | $ | - | |
Exhibit II – (Revised)
SEC Comment Letter 5
INFUSIONS BRANDS INTERNATIONAL, INC. AND SUBSIDIARIES
The components of comprehensive income for the years ended June 30, 20XX and 20XX and for the six months ended December 31, 20XX and 20XX respectively, are as follows:
| | | Year | | | Six Months | |
| | | Ended | | | Ended | |
| | | June 30, | | | December 31, | |
| | | 20XX | | | 20XX | | | 20XX | | | 20XX | |
| | | | | | | | | | | | | | | | | |
| Net income | | $ | —- | | | $ | — | | | $ | — | | | $ | — | |
| Other comprehensive income: | | | | | | | | | | | | | | | | |
| Change in unrealized gains (losses) of available for sale investments | | | — | | | | — | | | | — | | | | — | |
| | | | | | | | | | | | | | | | | |
| Total other comprehensive income | | | — | | | | — | | | | — | | | | — | |
| | | | | | | | | | | | | | | | | |
| Comprehensive income | | | — | | | | — | | | | — | | | | — | |
| Comprehensive income attributable to the non-controlling interest | | | — | | | | — | | | | — | | | | — | |
| Comprehensive income attributable to Infusion Brands International, Inc. | | $ | — | | | $ | — | | | $ | — | | | $ | — | |
