L. STEPHEN ALBRIGHT
ATTORNEY AT LAW
17337 Ventura Boulevard, Suite 208
Encino, California 91316
Ph. (818) 789-0779 o Fax (818) 784-0205
LStephenAlbright@aol.com
February 9, 2006
VIA FAX, FEDERAL EXPRESS & EDGAR
Janice McGuirk, Esq.
SECURITIES & EXCHANGE COMMISSION
Division of Corporate Finance, Office of Small Business Review
450 Fifth Street N.W.
Washington, D.C. 20549
Re: FUTURA PICTURES, INC, (THE "COMPANY")
FORM SB-2, AMENDMENT NUMBER 4 ("FOURTH AMENDMENT")
ORIGINAL FILING DATE: MARCH 28, 2005
PRIOR AMENDMENTS: MARCH 30, 2005, JULY 15, 2005, AND NOVEMBER 29, 2005
SEC FILE NO.: 333-123611
Dear Ms. McGuirk:
I am in receipt of a copy of the Commission's January 6, 2006 comment letter to
Mr. Buddy Young of the Company. Please consider this letter to be the Company's
formal response to the Commission's latest comment letter. As required, we are
enclosing three (3) clean hard copies of the Fourth Amendment, with exhibits and
three (3) complete redlined copies of same, without exhibits. The redlined
copies are marked to show the changes in the format provided by Microsoft Word.
Thus, additions are highlighted in the body of the text and deletions are noted
in the right margin.
We will be responding to comments in the order presented and with the same item
numbers.
USE OF PROCEEDS, PAGE 8
Comment No. 1. The Fourth Amendment has been revised to respond to the
staff's comments and to reconcile any inconsistencies. The revisions should be
in compliance with the staff's comments.
MARKET FOR COMMON EQUITY, PAGE 9
Comment No. 2. The Fourth Amendment has been revised to respond to the
staff's comments. In particular, the language which stated that "securities
quoted in the Pink Sheets must be registered with the Commission" has been
deleted. This revision should be in compliance with the staff's comments.
Ms. Janice McGuirk
February 9, 2006
Page 2
PLAN OF OPERATION, PAGE 11
Comments No. 3. The Fourth Amendment has been revised to respond to the
staff's comments. The revisions should be in compliance with the staff's
comments.
Comment No. 4. The Promissory Note is filed with the Fourth Amendment as
Exhibit 10.3 This revision should be in compliance with the staff's comments.
Comment No. 5. The Fourth Amendment has been revised and updated to respond
to the staff's comments. The revisions should be in compliance with the staff's
comments.
LIQUIDITY AND CAPITAL RESOURCES, PAGE 13
Comment No. 6. The Fourth Amendment has been revised and updated to respond
to the staff's comments. The revisions should be in compliance with the staff's
comments.
Comment No. 7. The Fourth Amendment has been revised to respond to the
staff's comments. The revisions should be in compliance with the staff's
comments.
DEVELOPMENT OF BUSINESS, PAGE 14
Comment No. 8. The Fourth Amendment has been revised to respond to the
staff's comments. The revisions should be in compliance with the staff's
comments.
EXHIBIT 23.1
Comment No. 9. The auditor's consent submitted with the Fourth Amendment has
been revised to respond to the staff's comments. The revisions should be in
compliance with the staff's comments.
CLOSING COMMENTS
Finally, there have not been any material developments since the filing of the
Third Amendment to Form SB-2 Registration Statement and therefore no "Recent
Developments" section has been inserted in this Fourth Amendment to Form SB-2
Registration Statement. However, please be aware that the Company has updated
its financial statements which are current through November 30, 2005.
Sincerely,
/S/ L. STEPHEN ALBRIGHT
--------------------------
L. STEPHEN ALBRIGHT
enclosures
c: Buddy Young, w/encls