May 10, 2005

Mr. John Cash
Accounting Branch Chief
Division of Cooperative Finance
US Securities and Exchange Commission
450 Fifth Street
Washington, D.C.  20549

Dear Mr. Cash:

Thank you for your letter dated April 26, 2005.

1) We will revise our disclosure to show any
individual product revenue which accounts for ten
percent or more of consolidated revenue.

2) We disagree with your interpretation of APB 28
as it pertains to our financial statement
presentation.  We feel that the intent of APB 28 is
to allow a registrant to allocate expenses among
the quarters to accurately match revenue with
expenses. We believe that our analysis of our
advertising expense and corresponding sales
(Exhibits A, B, C and D) shows that the advertising
we spend in the first and second quarters clearly
impacts our sales in the third and fourth quarters.
To expense the advertising, as you suggest, would
cause us to mislead the public into thinking that
we are spending a higher percentage of our revenue
on advertising than we plan and cause us to show
losses in some periods and gains in others simply
based on when specific ads ran, even though some
related sales clearly occur in subsequent periods.
By spreading our advertising over the interim
periods (which we believe is in accordance with APB
28), we enable the public to judge how the company
is performing each quarter relative to the prior
quarters in the current fiscal year and the same
quarter of the previous year.  Therefore, the
public cannot be mislead by our spending more
advertising in one quarter relative to the next.

We do report our advertising expense on an annual
basis in accordance with SOP 93-7, whereby all
advertising incurred during the year is expensed
during the same year. As discussed in the May 1994
issue of The CPA Journal (Exhibit E), SOP 93-7 does
not apply to interim periods and refers us back to
APB 28, which as we said above we believe we comply
with.

3) We allocate those items which EITF 01-9
describes as "sales incentives" (ie. Slotting
allowances) to sales and leave the cost of ads run
by the retailers as part of our advertising
expense. We reduce our revenue according to the
guidance of EITF 00-14 and EITF 01-9 for those
items for which we receive no identifiable benefit.
If the incentive is related to "free goods" we
recognize the expense as part of our cost of goods.
If it is simply a cash discount or allowance we
recognize it as a reduction of sales.  If the
allowance is for cooperative advertising run by the
retailer we issue a credit when the retailer proves
that the advertising did in fact run. We account
for that as advertising expense.

4) We believe we did respond to all of your
questions posed in your previous comment number 11.
What, specifically, did we not clarify?  We account
for our royalty costs as part of our SG&A. We
followed the guidance of our auditors and examples
found in PPC's (Practitioners Publishing Company)
Fifteenth Edition of Guide to Preparing Financial
Statements  Trends Volume page IS-20 which show
royalties as an operating expense (Exhibit F). We
believe only costs associated with acquiring and
producing our product should be shown as cost of
goods sold.  Royalty expense is based on the sales
volume we do and is not a part of the expenses
incurred to arrive at the cost of goods available
for sale.

Please let us know if there is anything else you
wish us to explain or amend in our 10K.   If not,
we will amend our 10K as we have described in our
letters and resubmit it for your approval. We will
also take all of your suggestions into
consideration in all of our future filings. Based
on our research and conclusions we do feel that it
is necessary at this time to amend the 10Q's for
the expensing of the advertising expense and as we
said above we already comply with SOP93-7 for year
end purposes.

Very truly yours,


John Bingman
Chief Financial Officer