[LETTERHEAD OF STUBBS, ALDERTON & MARKILES, LLP]
JOHN J. MCILVERY
Partner
Direct Voice 818.444.4502
Direct Fax 818.444.6302
Mobile 626.705.0758
E-Mail jmcilvery@biztechlaw.com
March 14, 2008
VIA EDGAR AND FEDERAL EXPRESS
Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20549
Attn: Christopher Owings
Mail Stop 3561
Re: TALON INTERNATIONAL, INC.
AMENDMENT NO. 2 TO FORM 10-K/A FOR YEAR ENDED DECEMBER 31, 2006
FILE NO. 1-13669
Ladies and Gentlemen:
This correspondence is provided on behalf of Talon International, Inc.
(the "COMPANY") in connection with the filing with the Commission of the
Company's Amendment No. 2 to Annual Report on Form 10-K/A for the year ended
December 31, 2006 (the "10-K AMENDMENT"). The 10-K Amendment includes the
additional and amended disclosure that the Company proposed to make in our
response letter dated January 25, 2008 (the "RESPONSE Letter"), and in response
to the Staff's comment letter dated November 21, 2007.
In addition to the modifications described in the Response Letter, we
wish to advise you that the Company has made the following additional
modifications in the 10-K Amendment:
During the Company's further review of the 10-K Amendment with its
former auditors for the fiscal year ended December 31, 2004, the Company
determined that the bad debt disclosure separately identified on the Company's
Statement of Operations was not $8.5 million as included in the Company's
preliminary proposed 10-K Amendment provided to the Staff with the Response
Letter, but was actually $12.5 million. A post-closing adjustment made in 2004
was not previously identified in the earlier draft or in the detailed notes in
the Company's historical files. The adjustment for the correct amount has been
made in the Company's disclosures in the 10-K Amendment.
Securities and Exchange Commission
March 14, 2008
Page 2
If you have any questions or require any additional information or
documents, please telephone me at (818) 444-4502.
Sincerely,
/s/ John J. McIlvery
-----------------------
John J. McIlvery
Encl.
cc: Lonnie Schnell, Company CEO
Adam Phippen, SEC Staff Accountant
Anita Karu, SEC Attorney-Adviser