GREG MANNING AUCTIONS, INC.
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Larry Crawford 775 Passaic Avenue
Chief Financial Officer West Caldwell, New Jersey 07006
Executive Vice President Phone 800-221-0243 - 973-882-0004
lcrawford@gregmanning.com Fax 973-882-2981
www.gregmanning.com
January 26, 2005
VIA EDGAR
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Division of Corporation Finance
Securities and Exchange Commission
Washington, D.C. 20549
Attention: Deborah A. Wilson, Staff Accountant
Monica Brame, Staff Accountant
Re: Greg Manning Auctions, Inc.
10-K for the year ended June 30, 2004
File No. 1-11988
Ladies and Gentlemen:
Greg Manning Auctions, Inc. (the "Company" or "GMAI") is providing its
responses to the additional comment from the staff of the Division of
Corporation Finance (the "Staff") of the Securities and Exchange Commission (the
"SEC"), by letter dated January 11, 2005.
Form 10-K filed September 10, 2004
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Notes to Consolidated Financial Statements, page 37
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(1) Description of Business and Summary of Significant Accounting Policies
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Inventories, page 39
We noted your response to comment 6. What factors determine whether a
certain inventory item falls under the specific identification method
versus using an estimate to write-down inventory based on a percentage of
the inventory aging by category? Also, clarify for us whether items are
subject to a write-down under both methodologies. Please include support
for your accounting in using both methodologies.
As we disclosed, our inventories are stated at the lower of cost or market
("LCM"), which reflects management's estimates of net realizable value.
Inventories are accounted for under the specific identification method.
Trusted By Serious Collectors ....Worldwide
NASDAQ symbol: GMAI
GREG MANNING AUCTIONS, INC.
In instances where bulk purchases are made, the cost allocation is based on the
estimated market values of the respective goods. The Company periodically
reviews the age and turnover of its inventory to determine whether any inventory
has declined in value and incurs a charge to operations for such declines. The
Company records write-downs based on two methodologies; specific write-downs on
certain items based on declines in the marketplace, and estimated write-downs
based on a percentage of the inventory aging by category type, unless the
Company implores a marketing strategy to sell goods over time.
The factors which determine whether certain inventory items are written down
under the specific identification method generally include the supplies of these
collectibles available in the market place, the popularity of these
collectibles, competition among dealers and merchants of collectibles and market
conditions. When conditions are unfavorable for specific inventory items we
adjust these items to an estimate of net realizable value for that specific
item.
We generally provide an estimated write-down based upon a percentage of
inventory aging by category type. We have performed quantitative analysis by
collectible type and have determined the following percentages:
Stamps
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Aged for greater than 1years 25%
Aged for greater than 2 years 50%
Aged for greater than 3 years 100%
Sports
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Aged for greater than 3 years 100%
Aged for greater than 2 years 50%
The coins category is not included in the above because coins inventory
generally turns several times a year. Accordingly a specific allowance is
provided for when necessary.
The exception to the above aging methodology is if we have employed a strategic
marketing plan, based upon our knowledge of the industry and marketplace, that
certain inventory, which is held longer than one year in order to avoid flooding
the market, and potentially depressing the selling price is excluded from this
methodology. This inventory is reflected as long-term in our financial
statements. However if factors change, we will consider these amounts in our
methodology in the future. Generally, if an item has a specific reserve it is
excluded from the aging methodology.
At June 30, 2004 and 2003, the above inventory amounts reflect net realizable
("LCM") allowances of $1,439 and $1,885, respectively. The percentages of this
allowance to total inventory are approximately 3% and 10% for the years ended
June 30, 2004 and 2003 respectively. We believe our methodology is consistent
with Accounting Research Bulletin No. 43 and our inventories are stated at the
lower of cost or market.
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GREG MANNING AUCTIONS, INC.
Should you have any questions in regard to this response, please call me
at 973-882-0004.
Very truly yours,
/s/ Larry Crawford
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Larry L. Crawford
cc: Mr. Greg Manning