June 4, 2007


Securities and Exchange Commission
Division of Corporation Finance
100 F Street, NE
Washington, D.C.  20549-3561

ATTN:  William Choi, Branch Chief

RE:  Form 10-KSB for the Fiscal Year Ended September 30, 2006;
     Forms 10-QSB for the Fiscal Quarters Ended December 31, 2006
       and March 31, 2007;
     File No. 0-13757


Dear Mr. Choi:

We are in receipt of your letter dated May 21, 2007, with respect to the
above-captioned filings.  The following addresses the Staff's comments set
forth in your letter, and for convenience purposes, the numerical order and
numbering of our responses corresponds with the Staff's comments.

Form 10-KSB for the Fiscal Year Ended September 30, 2006
- --------------------------------------------------------

1.  General
- -----------
Please note that the Class A Preferred Stock (the "Preferred Stock") that is
owned solely by the Company's principal shareholder was the only outstanding
potentially dilutive security, as of the date of the filing, which is
convertible into the Company's Common Stock (the "Common Stock"), and subject
to Paragraph 40c of SFAS 128.  The requirement of Paragraph 40a of SFAS 128 to
reconcile the numerators and the denominators of per share computations was not
applicable to the Company's filing, where no diluted per share computations
were required because the generation of losses by the Company was
anti-dilutive.  However, while the basic per share computations were calculated
correctly, the effect of the Preferred Stock dividends on the numerator of the
basic per share computations was not separately disclosed as required by
Paragraph 40b of SFAS 128.  Appropriate disclosure will be added in future
filings with respect to the foregoing.

Paragraph 41 was inapplicable at the time of issuance of the September 30,
2006, annual financial statements.  (Such a disclosure was applicable and made
in the interim financial statements presented in the Company's Quarterly
Report of Form 10-QSB for the period ended March 31, 2007.)


2.  Notes to Consolidated Financial Statements
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     4. Related Party Transactions
     -----------------------------
As discussed in Note 4 to the financial statements, the subject transaction
did not entail any conversion provisions contained among the initial terms of
the debt instruments but rather was the result of the Company's principal
shareholder agreeing to convert the debt, which was approved at a special
meeting of the Company's stockholders held on January 20, 2006.

Mr. William Choi
Securities and Exchange Commission
June 4, 2007
Page 2

o       As also disclosed in Note 4 to the financial statements, on the face
        of the balance sheet, and as also described in the Proxy Statement
        related to the special meeting of stockholders held on January 20,
        2006, the Preferred Stock is convertible and earns dividends at a 3%
        annual rate.  A summary containing additional detail about the
        pertinent rights and privileges associated with the Preferred Stock
        pursuant to SFAS 129, paragraph 4, as is illustrated below, will be
        included in future filings.

o       The class of Preferred Stock par value $.0005, was authorized and
        created solely for the purpose of converting the then outstanding
        debt of the related party and was structured such that its initial
        liquidation value of $2.00 per share was equal to its estimated fair
        value and thus, each share was issued and exchanged for $2.00 in
        outstanding debt, resulting in no gain or loss.  It should be noted
        that no shares of Preferred Stock are registered and available for
        trading and, thus, there is no established market value.  It should
        also be pointed out that had any other value been selected, the
        accounting result would have been the same.  This is because pursuant
        to SAB Topic 7B5, the Staff interprets APB 26, footnote 1 to paragraph
        20, as follows:  "Forgiveness of debt by a related party typically
        should be considered as a capital transaction."  Therefore, no matter
        what the estimated fair value of the stock, its par value would be
        credited to a capital stock account and the difference between that
        and the carrying value of the debt (consisting of the aggregate of the
        remainder of its estimated fair value adjusted for any unrecognized
        gain or loss) would be credited to additional paid-in capital.  The
        Company's balance sheet reflects the foregoing.

Proposed revision to note 4 regarding preferred stock in future filings:

  Per the Staff's comments, we propose that substantially the following
  language be included in future filings in the notes to our financial
  statements:

  Prior to 2005, the Company borrowed $1,000,000 from its principal officer/
  shareholder, Todd Axelrod.  The advance was due on demand but not prior to
  October 31, 2007, with monthly interest payments payable at a rate of 6% per
  annum (reduced from 8% as of September 2005).  Interest expense on the
  related party advance was $60,833 and $79,333 for fiscal years 2006 and
  2005, respectively.  The Company has also borrowed other amounts, from Mr.
  Axelrod, from time to time during the fiscal years 2006 and 2005.  The funds
  borrowed had an interest rate of 1.5% above the prime lending rate but was
  reduced to 3% as of September 1, 2005.  The principal balance of the funds
  borrowed in addition to the foregoing $1,000,000 totaled $582,556 and
  $3,280,063 as of September 30, 2006 and September 30, 2005, respectively.
  Interest expense on these related party borrowings was $43,918 and $195,452
  during fiscal years 2006 and 2005, respectively.  The funds were used to
  supplement cash flows from operating activities.  On January 20, 2006, the
  Company held a special meeting of stockholders and approved converting
  $3,231,722 of the advances into 1,615,861 shares of Series A Convertible
  Preferred Stock.  The Series A Convertible Preferred Stock earns dividends
  at the annual rate of 3% applied to the liquidation value, and payable
  semi-annually so long as resources are legally available for that purpose


Mr. William Choi
Securities and Exchange Commission
June 4, 2007
Page 3

  (unless waived by the holder).  Unpaid dividends are cumulative, are added
  to the liquidation value (upon which the annual dividend rate is applied),
  and are preferential in the event of liquidation and with respect to any
  dividends or other distributions to Common Stockholders.  The Preferred
  Stock is non-voting (except as may be required by law) and convertible at
  any time at the option of the holder at a fixed rate of one common share
  for every $2 in liquidation value, as adjusted, per share of Preferred
  Stock at the time of conversion, subject to adjustment in the event of
  future increases or decreases in the number of outstanding shares of Common
  Stock for a price other than the then conversion price of the Preferred
  Stock or in the event of issuance of certain other securities.  As of
  September 30, 2006, a total of 1,640,099 shares of Common Stock were
  issuable upon conversion of the Preferred Stock.

Proposed parenthetical addition to balance sheet caption for preferred stock
in future filings:
  Per the Staff's comments, we propose that substantially the following
  language be included as a parenthetical addition to the balance sheet
  caption for the Preferred Stock:

  (liquidation value at September 30, 2006, $3,280,198, including cumulative
  unpaid dividends of $48,476 which are in arrears)


3.  Income Taxes
- ----------------
As reported initially in Note 12 to the Company's financial statements
contained in our Annual Report on Form 10-KSB for the year ended September 30,
2002, management made a prior period adjustment to retroactively reduce the
deferred tax asset valuation allowance as of October 1, 2000, and September
31, 2001 (the 2001 Restatement), by an aggregate of approximately $600,000
when management determined that it was appropriate under SFAS 109, paragraph
24(b), to consider unrecorded appreciation in the Company's inventory since it
could virtually control the realization of its net NOL carryforwards to the
extent it was able to liquidate such inventory, even at bulk wholesale prices,
as needed.  (As a historical side note, this approach was, in fact, used during
years ended September 30, 1998 and 1997, to utilize NOLs of approximately
$630,000 that were accumulated through September 30, 1996.

Contemporaneously with the 2001 Restatement, management retained a business
strategy / valuation consultant that assisted it in estimating the substantial
extent of unrecorded appreciation in the Company's inventory.  Management
believes that current gross profit margins of approximately 90% and other
approaches to value (such as market capitalization) continue to be supportive
of this conclusion.  As indicated repeatedly in the Company's filings over the
years, its business model includes retaining substantial amounts of inventory
not currently offered for sale so as to limit its availability and thus
preserve its rarity and maximize its appreciation.  As a result, a substantial
amount of appreciated inventory is always on hand.  While management is
increasing the number of inventory items listed for sale and is considering
modest pricing reductions to stimulate sales as more permanent operating
strategies than the one employed previously to utilize NOLs (when desired or
necessary), management believes that a bulk wholesale liquidation of inventory

Mr. William Choi
Securities and Exchange Commission
June 4, 2007
Page 4

continues to be a viable strategy and, as a result, that the Company is
effectively able to control the timing of realization of its deferred tax
assets, net of valuation allowances provided.



4.  Exhibits 31.1 and 31.2
- --------------------------
The introductory language in paragraph 4 will be removed in future filings
until we are required to include management's internal report in our annual
report.



5.  We will revise the certifications in accordance with the requirements of
    Item 601(b)(31) of Regulation S-B in future filings.



Form 10-QSB for the Quarter Period Ended March 31, 2007
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Notes to Consolidated Financial Statements
- ------------------------------------------
6.  Revenue-sharing Arrangement
- -------------------------------

o   The arrangement characterized as a revenue-sharing arrangement has, in
    fact and substance, some of the typical attributes of both consignment
    arrangements and agency relationships. Under the agreement between the
    parties, title to all documents remains with Mr. Axelrod until transferred
    to the end purchaser, along with all the risk and rewards of ownership,
    including all uninsured risks of loss associated with lack of authenticity
    or marketability other than resulting from the Company's own negligence
    arising from its custodianship service.  As disclosed in the note to the
    financial statements and the MD&A contained in the Company's Quarterly
    Reports of Form 10-QSB for the periods ended December 31, 2006, and March
    31, 2007, the Company physically stores and safeguards and the documents,
    catalogs and markets them in the capacity of a seller's agent for a fee
    consisting of 80% of the gross profit on each sold item.

o   Management has been unable to identify any authoritative or
    semi-authoritative accounting literature that speaks to the question of
    whether consigned or similarly non-owned items should be included in the
    inventory of the consignee or agent, but rather such literature applies
    principally to questions of revenue recognition by consignors.  However,
    the editorial material in CCH's Accounting Research Manager states that
    inventory should include items that are "[p]hysically on hand, other than
    items received on consignment or for which the significant risks of
    ownership have not passed to the buyer" [emphasis added].  Accordingly,
    based on these facts and considerations, management concluded, and the
    Company's independent auditors concurred, that since the substance of its
    possession pending sale of the items on behalf of Mr. Axelrod is similar
    to that of goods received on consignment, it would be inappropriate to

Mr. William Choi
Securities and Exchange Commission
June 6, 2007
Page 5

    include these documents in the Company's inventory.

o   In addition but related to the inventory question, consideration was given
    to whether the ultimate disposition of these documents to third party
    buyers should be presented gross, as simultaneous purchases and sales in
    the Company's statement of operations, as is typical for consignment sales,
    or net as, in substance, a fee for the services described in the preceding
    paragraph or a share of revenue much like contingent rent to a lessor (see
    also SAB Topic 8A and TPA section 5100.16) or a sales commission.  For this
    determination, substantial reliance was placed on an analysis based on the
    guidance in EITF 99-19. EITF 99-19 does not prescribe an accounting
    treatment for any given set of circumstances but rather requires that one
    evaluate a series of indictors of either gross or net treatment, to
    exercise considerable judgment in weighing the evidence on both sides of
    the issue, and to make a determination as to which method is more
    appropriate.  In doing so, it was determined that revenue would best be
    reported net in these circumstances.

o   Although the Staff has suggested that "each significant revenue-generating
    activity should be separately reported," management is unaware of such a
    requirement applicable to Reg. SB issuers.  Nevertheless, management
    believes that the revenue-producing activity that resulted in these fees,
    i.e., the marketing of historical documents to collectors and other
    dealers, is more than merely not significantly different from, it is
    precisely the same as, the activity that produces all of the other revenues
    of the Company.  Only the form of arrangement with the vendor (Mr. Axelrod,
    in this case) and, therefore, the character of the revenue, are different,
    not the activity.  Accordingly, management believes the disclosure in the
    notes, rather than on the face of the statement of operations, of the volume
    of such income of this different character, along with the details of the
    arrangement, should be sufficient to comply with GAAP and to meet both the
    needs of financial statement users and the applicable requirements of the
    SEC.

In responding to your comments the Company hereby acknowledges that:
    1.  the Company is responsible for the adequacy and accuracy of the
        disclosure in the filing;
    2.  Staff comments or changes to disclosure 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.

We trust that the foregoing are responsive to the Staff's comments.  Please do
not hesitate to contact us, if we can be of any further assistance.


Sincerely,

/s/ Rod Lynam
- -------------
Rod Lynam
Treasurer