[ESCALA GROUP LOGO]





June 26, 2006


VIA EDGAR
- ---------

Division of Corporation Finance
Securities and Exchange Commission
Washington, D.C. 20549
Attention:     Steven Jacobs, Accounting Branch Chief
               Rachel Zablow, Staff Accountant

                     Re:  Escala Group, Inc. (f/k/a Greg Manning Auctions, Inc.)
                          10-K for the year ended June 30, 2005
                          Form 10-Q for the quarter ended September 30, 2005
                          Form 10-Q for the quarter ended December 31, 2005
                          File No. 1-11988

Ladies and Gentlemen:

     Escala Group,  Inc. (the  "Company" or "Escala") is providing its responses
to the  comment  from the staff of the  Division  of  Corporation  Finance  (the
"Staff") of the Securities and Exchange  Commission (the "SEC"), by letter dated
June 7, 2006.

          Form 10-Q for the quarter ended September 30, 2005
          --------------------------------------------------
          Form 10-Q for the quarter ended December 31, 2005
          -------------------------------------------------

               Item  2 -  Management's  Discussion  and  Analysis  of  Financial
               Condition and Results of Operations, pages 26 and 31

2.   We have read your  response  to prior  comment  2. In light of the  ongoing
     investigation by Spanish authorities, please advise us in sufficient detail
     of  how  you  concluded  that  the   consideration   received  from  Afinsa
     approximates the fair value of the philatelic material supplied to Afinsa.

     At this time,  the Company has no factual basis upon which to conclude that
     the  consideration  received  from  Afinsa  exceeds  the fair  value of the
     philatelic  material sold to Afinsa. As a result,  the Company believes the
     appropriate   accounting   treatment   is  to   recognize  as  revenue  all
     consideration received from Afinsa for the philatelic materials supplied to
     Afinsa.

     As to the effect of the events in Spain in particular  on our position,  we
     understand from our Spanish  counsel that, as the Staff notes,  this matter
     is in the  investigative  phase.  We understand this phase may continue for
     years.  As we also  understand,  it is only at the conclusion of this phase
     that the Spanish court in question will determine whether there are grounds
     to continue to the next phase,  which is a trial  before a competent  court
     based on written  charges,  or whether the proceedings  should be dismissed
     because  of  insufficient  evidence.  The  trial  will  result  in either a
     conviction or an acquittal.




  Escala Group, Inc. 623 Fifth Avenue, 27th Floor. New York, New York 10017-USA
          Phone 212 421 94 00 / Fax 212 860 86 67 / www.escalagroup.com
                               NASDAQ symbol: ESCL



Division of Corporation Finance
Page 2


     In view of the fact  that the  investigation  in Spain is still in its very
     early stages, and that, to our knowledge, there has been no finding reached
     that the fair market value of the material  actually sold by the Company to
     Afinsa  was  anything  less  than  what  Afinsa  paid the  Company  for the
     material,  we do not believe it would be  appropriate  for us to modify our
     accounting  treatment on that basis alone.  As we noted in our last letter,
     however,  the  investigation in Spain has led the Board of Directors of the
     Company to request that its Audit Committee  independently  investigate the
     transactions  between the Company and  Afinsa.  If the  Company's  position
     changes as a result of this  investigation  or otherwise,  the Company will
     inform the Staff promptly.

                                      - - -



     The Company acknowledges that:

          o    the Company is  responsible  for the adequacy and accuracy of the
               disclosure in the filing;
          o    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
          o    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.

Should you have any  questions  in regard to this  response,  please  call me at
212-421-9400.



                                        Very truly yours,

                                        /s/ Matthew M.Walsh

                                        Matthew M. Walsh