0000084112-11-000006.txt : 20110603 0000084112-11-000006.hdr.sgml : 20110603 20110408102510 ACCESSION NUMBER: 0000084112-11-000006 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20110408 FILER: COMPANY DATA: COMPANY CONFORMED NAME: RISK GEORGE INDUSTRIES INC CENTRAL INDEX KEY: 0000084112 STANDARD INDUSTRIAL CLASSIFICATION: COMMUNICATIONS EQUIPMENT, NEC [3669] IRS NUMBER: 840524756 STATE OF INCORPORATION: CO FISCAL YEAR END: 0430 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 802 SOUTH ELM STREET 2: GRI PLAZA CITY: KIMBALL STATE: NE ZIP: 69145 BUSINESS PHONE: 3082354645 MAIL ADDRESS: STREET 1: 802 S ELM ST CITY: KIMBALL STATE: NE ZIP: 69145 CORRESP 1 filename1.txt GEORGE RISK INDUSTRIES, INC. 802 S. ELM ST. KIMBALL, NE 69145-1599 PHONE: 308-235-4645 FAX: 308-235-2554 E-MAIL: gricfo@embarqmail.com April 8, 2011 UNITED STATES SECURITIES AND EXCHANGE COMMISION Division of Corporation Finance 100 F St. NE Washington, DC 20549 Dear Larry Spirgel: This letter is in response to the letter you sent me dated March 17, 2011 concerning George Risk Industries, Inc. Form 10-K for the fiscal year ended April 30, 2010. This letter will reference your letter via heading and numeration as was set forth in the above mentioned letter you sent to me. 1. Item 1. Business, page 3 ---------------------------- We have just recently obtained a written agreement with the distributor that accounts for 43% of our security segment sales. This agreement was signed in February 2011 and was initiated by the customer. The contents of this agreement have to do with product terms, purchasing, payment terms, term and termination, product marketing, representations and warranties, product support, mutual confidentiality, indemnification and insuarnce, and general provisions. This agreement will be filed as an Exhibit in future 10-K filings. 2. Item 5. Market for the Registrant's Common Equity and Related Stockholders' Matter, page 5 ----------------------------------------------------------------- On all future filings, we will account for the repurchase of common stock made by the company on a quartely basis on the Forms 10K and 10Q. I will provide disclosures covering repurchases made on a monthly basis as is re- quired by Item 703 of Regulation S-K. 3. Item 7. Management's Discussion and Analysis of Financial Condition and Results of Operations, page 6 Executive Overview, page 6 --------------------------------------------------------------------------- On all future filings, there will be greater discussion in this area of how our marketable securities holdings play a part on our financial results. Within this discussion we will give management's philosophy on how these in- vestments complients and impacts our core business. 4. Item 7. Management's Discussion and Analysis of Financial Condition and Results of Operations, page 6 Results of Operations, page 7 --------------------------------------------------------------------------- On all future filings, there will be more discussion about material changes in financial statement line items and how they affect financial results. 5. Item 10. Directors and Executive Officers of the Registrant, page 36 ------------------------------------------------------------------------ On all future filings, we will provide the information required by Regulation S-K Items 405 and 406 in this item. In addition, we will provide all the necessary informaion under Regulation S-K Item 401. The company, George Risk Industries, Inc., acknowledges that 1) we are responsible for the adequacy and accuracy of the disclosure in the fillings; 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 filings; and 3) we may ot assert staff comments as a defense in any pro- ceedings initiated by the Commission or any person under the federal securities laws of the United States. Sincerely, /s/ Stephanie M. Risk Stephanie M. Risk Chief Financial Officer