DGSE COMPANIES, INC.
11311 REEDER ROAD
DALLAS, TEXAS 75229
December 23, 2009
MR ..William Thompson
Accounting Branch Chief
United States Securities and Exchange Commission
Washington, DC 20549-0450
RE: Commission Review Comments Dated December 10, 2009
DGSE Companies
File No. 1-11048
Dear Mr. Thompson:
We hereby offer our response to the Commission’s comments:
1. | We agree that impairment losses related to marketable securities are properly classified as non-operating expenses and will be classified as such in our amended filings. |
2. | Note 10 will be amended to include all outstanding warrants that were dilutive for the year ended December 31, 2007. |
3. | The Form 10-Q for Fiscal quarter ended September 30, 2009 will be amended to provide the certification required by Rule 13a-14(b) (17CFR240.13a-14(b)) or Rule 15d-14(b) (17CFR240.15d-14(b)) and section 1350 of Chapter63 of Title 18 of the United States Code (18 U.S.C. 1350). |
4. | The Form 10-Q for Fiscal quarter ended September 30, 2009 will be amended to provide the certification by our Chairman and Chief Executive Officer to conform to Item 601(b)(31) of Regulation S-K. |
The Company acknowledges that:
A. | the Company is responsible for the adequacy of the disclosure in the filings; |
B. | staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filings; and |
C. | the Company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under federal securities laws of the United States. |
DGSE Companies, Inc.
By: s/John Benson
Chief Financial Officer