SHEPARD INC.
318 - 470 GRANVILLE STREET
VANCOUVER, BRITISH COLUMBIA
CANADA V6C 2B3
TELEPHONE: (604) 719-8129
FACSIMILE: (604) 688-8872
September 30, 2005
U.S. Securities & Exchange Commission
Division of Corporate Finance
450 Fifth Street, N.W.
Washington, D.C. 20549
Mail Stop 0305
Attention: Anita Karu
Dear Sirs:
Re: Shepard Inc. - Registration Statement on Form SB-2 - File #333-124632
Further to your letter dated September 22, 2005 concerning the deficiencies in
our registration statement on Form SB-2, we provide the following responses:
Financial Statements
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2. Summary of Significant Accounting Policies
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d) Foreign Currency Translation, page 35
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1. We read your response to comment 3 from our letter dated July
21, 2005. You indicate on page 35 that gains or losses on foreign
currency translation are included in the statement of operations. Pleas
revise your disclosure to indicate that such gains or losses are not
included in determining net income but are reported tin other
comprehensive income or tell us why such revision is unnecessary.
Please refer to paragraph 13 of SFAS 52.
As appropriate, please amend your registration statement in response to
this comment. You may wish to provide us with marked copies of the
amendment to expedite our review. Please furnish a letter with your
amendment that keys your responses to our comment and provides any
requested information. Detailed letters greatly facilitate our review.
Please understand that we may have additional comments after review
your amendment and responses to our comment.
Further to our telephone conversation with David DiGiacomo of your
office, we confirm that our functional currency is the U.S. dollar.
Gains and losses on foreign currency translation are included in the
statement of operations.
Yours truly,
/s/ Michael Eyre
Shepard Inc.
Michael Eyre, President