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
February 14, 2005
VIA EDGAR
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Division of Corporation Finance
Securities and Exchange Commission
Washington, D.C. 20549
Attention: Donna DiSilvio, Senior Staff Accountant
Monica Brame, Staff Accountant
Re: Greg Manning Auctions, Inc.
10-K for the year ended June 30, 2004
File No. 1-11988
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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 February 1, 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
1. Please confirm our understanding of your response to comment 1 that items
are subject to a write-down using either one of two methods applied
consistently.
Your understanding is correct: We utilize either one of the two methods on
a consistent basis.
Trusted By Serious Collectors ....Worldwide
NASDAQ symbol: GMAI
2. How often are strategic marketing plans giving rise to exceptions with the
aging methodology? In this regard, please clarify for us and in future
filings disclose the method used to write-down inventory subject to a
marketing strategy to sell goods over time.
As we have disclosed, the classification of inventory as "long-term" is made
whenever there is a strategic marketing plan in place to sell the inventory over
a period of time, greater than one year. These plans are put into place
generally as an effort to avoid "flooding the marketplace" and potentially
depressing the selling price. We monitor this inventory on a continual basis and
if factors change, we write down the inventory to its estimate of net realizable
value. Over the past five years we have identified four unique collections in
which we have employed a strategic marketing plan to sell this inventory. One of
these collections was sold over a two- to three -year time period at our
expected gross margin without any write-downs of inventory. The second
collection was written down to net realizable value as result of changes in
market conditions, and was subsequently sold. The remaining two collections are
currently classified as long-term inventory and are being monitored quarterly.
_ _ _
The Company acknowledges that:
o the Company is responsible for the adequacy and accuracy of the
disclosure in the filing;
o 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
o 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/
Should you have any questions in regard to this response, please call me at
973-882-0004.
Very truly yours,
/s/ Larry L. Crawford
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Larry L. Crawford
cc: Mr. Greg Manning