June 27, 2005

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

Dear Mr. Cash:

Thank you for your courtesy in extending the time for us to
respond to your letter dated June 7, 2005

We would like to acquaint you with the manner in which our
Company handles its media advertising purchasing.  This
methodology, we believe, has worked quite successfully.  The
issue we are addressing is the financial reporting of our interim
advertising expensed when reporting our quarterly 10Q financial
statements.

The AICPA's Accounting Standards Executive Committee issued a
Statement Of Position in May 1994 (SOP 93-7), Reporting on
Advertising Cost.  They stated that the guidance provided by SAS
No. 69"does not apply to financial statement for interim
periods."  APB Opinion No 28, Interim Financial Reporting,
paragraphs 15 and 16 provide guidance for interim periods.

APB No. 28 provides:

     d. Advertising costs may be deferred within a fiscal
     year if the benefits of an expenditure made clearly
     extend beyond the interim period in which the
     expenditure is made.  Advertising costs may be accrued
     and assigned to interim periods in relation to sales
     prior to the time the service is received if the
     advertising program is clearly implicit in the sales
     arrangement.

We believe that our previously submitted schedules of the
expenditures made quarterly and the yearly results as a result of
the earlier expenditures substantiate our current accounting
presentation.

However, there are four ways in which our interim accounting
presentations could be presented in accordance with your
preliminary comments.  To determine which presentation most aptly
relates to our advertising merchandising of our products, an
overview of our procedures will provide a basis for determining a
fairly presented interim accounting position.



Overview of Purchase of Advertising for a Fiscal Year.

To compete in our industry requires a careful consideration of
how and when to promote our products.  The first quarter is the
commencement of advertising for our regular product lines with
new packaging and the new SKU presentations which we want to put
on the shelves throughout the country.  In the second quarter all
the SKUs are in place and the advertising creates consumer demand
for our products at the highest level.    During the third summer
quarter sales, our advertising expense is significantly less
because the consumer is on vacation, at the beach or spending
more time outdoors than watching television.  The fourth quarter
is the Christmas preparation time with special packaging for
shelf space during the season.  Most advertising is related to
Christmas gifts, not normal every day staple products like ours.
Advertising for our products would get lost during the Christmas
season.

On or about October, we begin to purchase advertising time for
the next fiscal year (beginning December 1).  During this time,
we usually purchase 75% of our overall advertising for the coming
year.  We do not determine exactly which product we actually
intend to advertise.  We focus mostly on beginning our
advertisements in the first quarter with the heaviest
expenditures in the second quarter when there will be strongest
demand for our products.  Usually within a short time frame
before the advertising is to run, we try to coordinate with co-op
promotions and decide which products to advertise.

We will spend 75 to 80% of our overall advertising budget in the
first two quarters.  We still have approximately 20% of our
budgeted advertising expenditures available for the third and
fourth quarters on a spot purchasing basis to plug into the
market on whatever product we feel requires a boost and whatever
market we want to reinforce from our prior advertising expended
during the first half of the year.

We are free to use our advertising throughout the year on any
product in any market place that we feel will provide the best
results.

With the above in mind, I would like to review the five various
advertising accounting presentations that would reflect our
business operations.

A.   Current Accounting Interim Presentations

Our current pro rata accounting interim presentation has
previously been discussed in our prior response to our comments.
(See Schedule A-I annexed hereto.)

B.   Advertising Charge to Quarterly Statement of Operations When
     Advertising Actually Runs -No Quarterly Accruals

This method of interim accounting was referred to in our response
to your letter on May 10, 2005.  We attempted to provide
information that our advertising in the first and second quarters
is actual "pump priming" and has a direct impact on our sales in
the third and fourth quarters.



We believe that if we were required to adopt this method, it
would cause substantially uneven quarterly results and would not
enable the shareholders to fairly judge the Company's quarterly
performance.  As a public Company, the market is sensitive to the
"bottom line."  Using this method would negatively skew the
picture of a healthy company by showing less profit in the best
revenue producing quarters and more profit in the quarters with
less revenue.  (See Schedule B-II annexed hereto.)

C.   The Method Employed by a Competitor in the Health and Beauty
     Aid Industry

This method requires the company to make two determinations prior
to the beginning the new fiscal year, i.e.:

       .    estimated amount of revenue anticipated
       .    estimated advertising to be purchased.

 For each quarter thereafter, the company deducts (as a
percentage of anticipated revenues), the projected expenditures
from the sales of each product.  For example, if sales were
projected at $200 million and advertising expenses were projected
at $20 million, each dollar of sales would require expensing 10%
for advertising.  At year's end, the company would make whatever
adjustments are required to record the actual expenditures made
and reflect these adjustments in the fourth quarter.

This method, like our current method, reflects the exact
advertising expenditures to be charged in the year end statement.
This method, like ours, spreads the cost out over the year
without burdening any one or two quarters.  (See Schedule C-III
annexed hereto.)


D.   Matching of Advertising Cost by Product

This method might be somewhat more speculative than assuming the
sale of all products to arrive at a percentage.  As discussed in
the "overview," we do not really know in advance what advertising
costs would be spent on any one product line.  Things change
throughout the year.  Every year a different product may have its
"day in the sun" or it may lose some market share.  (See Schedule
D-IV annexed hereto.  This schedule only records the actual
advertising expense history.  Expenses were not based on a
predetermined marketing plan on a firm basis.) We believe that
having to work with highly volatile estimates of revenues and
advertising by product line could require a substantial
adjustment in the fourth quarter operating results.

Conclusion

We have presented the proforma schedules to analyze the effect
upon the interim quarters as summarized in Schedule E-V attached
hereto.  We suggest that CCA use either Method A or C.   We
believe that expensing advertising expense ratably over the




quarters is the fairest way to present the interim statement of
operations (Our current method "A").  Method "B" Schedule B-II,
we believe would show a quarterly aberration on earnings.
Schedule C-III "C" is the closest to the ratable charge per
quarter; and, Method "D" is the method that would require
substantial year-end adjustments.

We await your comments and of course, we will adopt whatever
method you determine is most reflective of quarterly results.  We
do request that no change is made during this fiscal year, but
the change can be instituted beginning fiscal 2006.  We
respectfully suggest that we have used the ratables expense for
the past 20 years and we would like to maintain our current
financial reporting procedure.  From an accounting conclusion,
all four positions end with the exact year-end results.

We understand that (1) we are responsible for the accuracy and
adequacy of the disclosures in our filings, (2) staff comments or
changes to disclosures in response to staff comments do not
foreclose the Commission from taking any action with respect to
the filing, and (3) the Company may not assert staff comments as
a defense in any proceeding initiated by the Commission or any
person under the federal securities laws of the United States.


Very truly yours,



John Bingman
Chief Financial Officer

/js

cc: Patricia Armelin
    Staff Accountant