CORRESP 1 filename1.txt Kings Road Entertainment 447 B Doheny Drive Beverly Hills CA 90210 T 310 278 9975 F 310 278 9974 kingsroadscreen@aol.com January 31, 2006 United States Securities and Exchange Commission Division of Corporate Finance Mail Stop 3561 Attn: Linda Cvrkel Claire Erlanger Washington, D.C. 20549 Re: Kings Road Entertainment, Inc. Form 10-KSB for the Fiscal Year Ended April 30, 2004 Forms 10-QSB for the quarters ended July 31, 2004, October 31, 2004 and January 31, 2005 Commission File No. 000-14234 Dear Ms. Cvrkel and Ms. Erlanger: We have reviewed your letter dated January 19, 2006 and in response to your comments regarding: Quarterly Report on Form 10-QSB for the quarter ended October 31, 2004 Note 2 ----------------------------------------------------------------------------- Litigation ---------- We will in all future filings expand our disclosures to include (i) a discussion of legal counsel's opinions with regard to likelihood of collection in all litigation matters, (ii) a listing of the reasons we believe recovery of receivables in these matters is either probable or is not probable, and (iii) the reasons behind not establishing an allowance for any receivables should that be the case at hand. Sincerely, /s/ H. Martin DeFrank ___________________________________ H. Martin DeFrank President and Chief Operations Officer Kings Road Entertainment, Inc.