Mail Stop 6010
August 9, 2005
Jeffrey T. Slovin
Chief Executive Officer
Schick Technologies, Inc.
30-00 47th Avenue
Long Island City, NY 11101
Re: Schick Technologies, Inc.
Annual Report on Form 10-K for the fiscal year
ended March 31, 2005
File No. 0-22673
Dear Mr. Slovin:
We have reviewed your filing and have the following
comments.
Where indicated, we think you should revise your document in
response
to these comments. If you disagree, we will consider your
explanation as to why our comment is inapplicable or a revision is
unnecessary. Please be as detailed as necessary in your
explanation.
In some of our comments, we may ask you to provide us with
information so we may better understand your disclosure. After
reviewing this information, we may raise additional comments.
Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects. We welcome
any questions you may have about our comments or any other aspect
of
our review. Feel free to call us at the telephone numbers listed
at
the end of this letter.
Annual Report on Form 10-K for the fiscal year ended March 31,
2005
Dependence on Customers, page 5
1. In future filings, please revise to discuss the material terms
of
the distributorship agreement.
2. Please file the complete agreement as an exhibit. We note that
you did not file Schedules I, II, III and IV of the April 6, 2000
agreement.
Patents, page 5
3. In future filings, please discuss the material terms of the
license with the California Institute of Technology.
4. Please file the license agreement as an exhibit.
Fiscal Year Ended March 31, 2005 as compared to Fiscal Year Ended
March 31, 2004, page 17
5. In future filings, please quantify the reasons for the change
in
revenues. For example, set forth as separate percentages the
increase in sales from Europe and Asia.
Evaluation of Disclosure Controls and Procedures, page 21
6. In future filings, please revise to clarify, if true, that your
officers concluded that your disclosure controls and procedures
are
also effective to ensure that information required to be disclosed
in
the reports that you file or submit under the Exchange Act is
accumulated and communicated to your management, including your
chief
executive officer and chief financial officer, to allow timely
decisions regarding required disclosure. See Exchange Act Rule
13a-
15(e).
Security Ownership of Certain Beneficial Owners and Management,
page
30
7. In future filings, please disclose the person who has or shares
voting power and or investment control over the shares held by
Greystone Funding Corp.
Revenue Recognition, page F-8
8. We note that you enter into arrangements with distributors to
sell
your products internationally. Tell us and revise future filings
to
explain the nature and significant terms of these arrangements,
including any post shipment obligations, acceptance provisions and
return provisions that may exist and how you account for such
obligations. Also, tell us and revise your filing to explain how
you
account for any price concessions or other incentives you offer to
your international distributors.
9. We note that for a limited time you are allowing your customers
to
trade-in their old digital radiography system for a new CDR
standard
system. Tell us how you are accounting for this promotion.
Discuss
how you account for the impact of the trade-in on the recognition
of
the sale of the new system. Also, discuss how you record the
returned equipment. Tell us whether this or any other trade-in or
upgrade rights are the result of written or verbal agreements with
any of your current or previous customers. If so, tell us how
these
terms impact your accounting for the original sales.
As appropriate, please amend your filing and respond to
these
comments within 10 business days or tell us when you will provide
us
with a response. You may wish to provide us with marked copies of
the amendment to expedite our review. Please furnish a cover
letter
with your amendment that keys your responses to our comments and
provides any requested information. Detailed cover letters
greatly
facilitate our review. Please understand that we may have
additional
comments after reviewing your amendment and responses to our
comments.
We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing includes all information
required under the Securities Exchange Act of 1934 and that they
have
provided all information investors require for an informed
investment
decision. Since the company and its management are in possession
of
all facts relating to a company`s disclosure, they are responsible
for the accuracy and adequacy of the disclosures they have made.
In connection with responding to our comments, please
provide,
in writing, a statement from the company acknowledging that:
* the company is responsible for the adequacy and accuracy of the
disclosure in the filing;
* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filing; and
* the company may not assert staff comments as a defense in any
proceeding initiated by the Commission or any person under the
federal securities laws of the United States.
In addition, please be advised that the Division of Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filing or in
response to our comments on your filing.
You may contact Tara Hawkins at (202) 551-3639 or Kevin
Vaughn
at (202) 551-3643 if you have questions regarding comments on the
financial statements and related matters. Please contact me at
(202)
551-3602 with any other questions.
Sincerely,
Thomas A. Jones
Senior Attorney
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Jeffrey T. Slovin
Schick Technologies, Inc.
March 2, 2006
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