[GRAPHIC OMITTED] [GRAPHIC OMITTED] TRUDY CORPORATION
353 Main Avenue
Norwalk, CT 06851-1552
Phone: +1.203.846.2274
Fax: +1.203.846.1776
July 20, 2005
Linda Cvrkel, Branch Chief, Division of Corporate Finance
RE: Trudy Corporation
In response to fax received June 22, 2005
File No. 0-16056
Dear Ms. Cvrkel,
We received your fax dated June 22, 2005. Below are the Company's
responses, with numbered answers corresponding to your inquiries.
1. The primary operating activity of the Company is the sale of books,
tapes & CD's of properties either licensed from third parties or owned outright
by the Company. On an opportunistic basis only the Company sublicenses its
licensed or owned properties, when this is allowed under the licensing
agreement. As such, sub-licensed sales are not part of the Company's day to day
operations. The company does not have a dedicated sales force, independent sales
representatives, expansion efforts or a marketing budget devoted to selling into
this channel of trade. As a result any sub-rights (sub-licensed) sales generated
are recorded as Other Income, net of related royalty expense which the Company
owes under its license agreement if required, since the Company believes these
revenues and expenses are an adjunctive part of the business.
Per your request, the below table illustrates sub-rights royalty revenues and
expenses for the periods indicated:
10K 10Q 10Q/A 10Q/A 10K
3/31/2004 6/30/2004 9/30/2004 12/31/2004 3/31/2005
---------- ---------- ---------- ---------- ----------
Sub-rights royalty income $ 93,492 $ 6,932 $ (2,491) $ 25,770 $ 42,811
Sub-rights royalty expense (19,937) 1,016 (2,775) (8,885) (11,225)
---------- ---------- ---------- ---------- ----------
Sub-rights royalties, net $ 73,555 $ 7,948 $ (5,266) $ 16,885 $ 31,586
========== ========== ========== ========== ==========
The Company will continue to monitor sub-rights revenues and expenses. To the
extent that this activity becomes either a significant part of the business or
the Company devotes greater resources to expanding this channel of trade, the
Company will record it as a component of operating income and make the
appropriate reclassifications.
2. The Company agrees with this comment and has revised its filings for
the quarters ended September 30 and December 31, 2004.
Summary of Adjustments made to Amended September 30 and December 31, 2004 Forms
1OQ
The filing for the quarter ended September 30, 2004 was amended to include the
$26,500 difference between the fair market value of the chief executive
officer's salary and the CEO's accepted salary of $1 per year.
The filing was also amended for a reclassification of royalty expense of $2,580
from royalty expense to Royalties, net included in Other Income/expense.
The filing for the quarter ended December 31, 2004 was amended for a
reclassification of royalty expense of $8,885 from royalty expense to Royalties,
net included in Other Income/expense. All adjustments made in the September
quarter were carried forward in the year to date results in the December 31,
2004 amended filing.
Sincerely,
/s/ WILLIAM W. BURNHAM
- ---------------------------------------
William W. Burnham
Chief Executive Officer and Acting Chief Financial Officer