January 19, 2006

Mail Stop 3561

Via US Mail and Facsimile

Mr. H. Martin DeFrank
President and Chief Financial Officer
447B Doheny Drive
Beverly Hills, California 90210

Re:	Kings Road Entertainment, Inc.
	Form 10-KSB for the year ended April 30, 2004
	Forms 10-QSB for the quarters ended July 31, 2004, October
31,
2004 and
      January 31, 2005
	Commission file #: 000-14234

Dear Mr. DeFrank:

We have reviewed your December 9, 2005 response letter and have
the
following comments.  Where expanded or revised disclosure is
requested, you may comply with these comments in future filings.
If
you disagree, we will consider your explanation as to why our
comments
are inapplicable or a revision is unnecessary.  We also ask you to
provide us with supplemental information so we may better
understand
your disclosure.  Please be as detailed as necessary in your
explanation.  We look forward to working with you in these
respects
and welcome any questions you may have about any aspects of our
review.


* * * * * * * * * * * * * * * * * * * * * * *

Quarterly Report on Form 10-QSB for the quarter ended October 31,
2004
Note 2. Litigation

1. We note from your response to prior comment 1 that you have not
established an allowance for the receivable based on anticipation
of
collection in full as advised by your legal counsel.  In future
filings, please expand your disclosure to discuss legal counsel`s
opinion on the likelihood of collection and the reasons you
believe
recovery of the $48,894 receivable is probable and why you have
not
established an allowance for the receivable.  Your additional
disclosure should be similar to your response included in your
December 9, 2005 letter.


* * * * * * * * * * * * * * * * * * * * * * *

As appropriate, please file your response to these comments via
EDGAR
within 10 business days or tell us when you will provide us with a
response.  Please furnish a cover letter that keys your responses
to
our comments and provides any requested supplemental information.

You may contact Claire Erlanger at 202-551-3301 or me at 202-551-
3813
if you have questions.


								Sincerely,



								Linda Cvrkel
								Branch Chief
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Mr. H. Martin DeFrank
Kings Road Entertainment, Inc.
January 19, 2006
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