LETTER 1 filename1.txt Mail Stop 4561 June 16, 2005 VIA USMAIL and FAX (218) 723-9779 Mr. David W. Montgomery VP Finance & Chief Financial Officer Advanstar Communications Inc. 131 W. 1st Street Duluth, MN 55802-2065 Re: Advanstar Communications Inc. Form 10-K for the year ended 12/31/2004 Filed 3/29/2005 File No. 333-57201 Dear Mr. David W. Montgomery: We have reviewed your above referenced filing and have the following comment. We have limited our review to only your financial statements and related disclosures and will make no further review of your document. As such, all persons who are responsible for the adequacy and accuracy of the disclosure are urged to be certain that they have included all information required pursuant to the Securities Exchange Act of 1934. In our comment, we may ask you to provide us with supplemental information so we may better understand your disclosure. Please be as detailed as necessary in your explanation. After reviewing this information, we may or may not raise additional comments. Please understand that the purpose of our review process is to assist you in your compliance with the applicable disclosure requirements and to enhance the overall disclosure in your filing. We look forward to working with you in these respects. We welcome any questions you may have about our comment or on any other aspect of our review. Feel free to call us at the telephone numbers listed at the end of this letter. FORM 10-K FOR THE YEAR ENDED DECEMBER 31, 2004 Financial Statements and Notes Report of Independent Registered Public Accounting Firm 1. Advise us how your audit report complies with Auditing Standard No. 1 of the PCAOB, References in Audit Reports to the Standards of the Public Company Accounting Oversight Board. * * * * As appropriate, please respond to this comment within 10 business days or tell us when you will provide us with a response. Please provide any requested supplemental information. Please file your supplemental information on EDGAR. Please understand that we may have additional comments after reviewing your response to our comment. We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing reviewed by the staff to be certain that they have provided all information investors require for an informed decision. Since the company and its management are in possession of all facts relating to a company`s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made. In connection with responding to our comment, please provide, in writing, a statement from the company acknowledging that * the company is responsible for the adequacy and accuracy of the disclosure in the filings; * staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filings; and * 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. In addition, please be advised that the Division of Enforcement has access to all information you provide to the staff of the Division of Corporation Finance in our review of your filing or in response to our comment on your filing. You may contact Wilson K. Lee, at (202) 551-3468 or me at (202) 551-3413 if you have questions. Sincerely, Cicely Luckey Branch Chief ?? ?? ?? ?? David W. Montgomery Advanstar Communications Inc. June 16, 2005 Page 1