Attn:
|
Sharon
Virga
|
1.
|
We
note your response to comment two in our letter dated November 17,
2010. Please amend your filings to revise your conclusion to
“not effective”.
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2.
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We
note your response to comment three from our letter dated November 17,
2010. We note that most of your returns are from your sales to
your wholesale customers comprised of two separate programs. In
this regard, we note that you have a return program for defective goods
within a specified period of time after shipment OR wholesalers are
granted a “defective allowance” consisting of a fixed percentage (between
1-5%) off of invoice price in lieu of returning products. With
regard to the total returns representing 12.3%, 9.4% and 8.6% as disclosed
on page 7, please tell us the percentage representing each of the two
separate defective return programs. Please note that sales
transactions, in which a customer may return defective goods, such as
under warranty provisions, are covered by paragraphs 5-7 of ASC
460-10-25. Please explain in detail your accounting for these
programs including the actual journal entries
made.
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Defective Return Program
|
||
Accrued
Sales Returns (contra sales account)
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$10,000
|
|
Deferred
Gross Profit on Estimated Returns
|
$10,000
|
|
To
accrue sales for estimated defective returns on Q1 sales.
|
||
Deferred
Gross Profit on Estimated Returns
|
$5,000
|
|
Cost
of Goods – Accrued Sales Returns (contra cost account)
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$5,000
|
|
To
accrue cost of sales for estimated defective returned goods on Q1
sales.
|
||
Deferred
Gross Profit on Estimated Returns
|
$3,000
|
|
Accounts
Receivable
|
$3,000
|
|
To
record credit memo for defective goods received from customer in
Q1.
|
||
Inventory
|
$1,500
|
|
Deferred
Gross Profit on Estimated Returns
|
$1,500
|
Defective Allowance Program
|
||
Accrued
Sales Returns
|
$5,000
|
|
Deferred
Gross Profit on Estimated Returns
|
$5,000
|
|
To
accrue sales for defective allowance granted on sales in
Q1.
|
||
Deferred
Gross Profit on Estimated Returns
|
$4,000
|
|
Accounts
Receivable
|
$4,000
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3.
|
With
respect to your defective return program, please tell us what percent of
total sales are comprised of sales to customers with a fixed “defective
allowance” percentage off invoice. If such returns are truly of
defective products, then they should be covered by ASC
460-10-25. Otherwise, tell us how you accounted for such sales
to these customers and refer to your basis in the accounting
literature. Did you adjust the selling price for sales of those
products subject to the percentage off invoice and thus only recognize
revenue in the same amount?
|
4.
|
It
was unclear from your response whether any returns were made for goods
shipped in error. Returns for goods shipped in error should not
be recognized as revenues as there was no basis to support revenue
recognition, since collectability was not reasonably
assured. Please advise.
|
5.
|
Tell
us more about your revision to your return policy whereby you have allowed
defective returns up to three additional months following the typical six
month return period. Do you only allow returns of defective
products or do you allow returns of products that are functioning
properly? Did you adjust this policy solely for your
wholesalers?
|
6.
|
Please
tell us more about your return policy for sales to wholesalers or
distributors for products that are not defective, if any. If
you have such a return policy, tell us why you believe you should
recognize such revenue when right of return exists. Refer to
ASC 605-15-25 in your response and explain in detail how you meet all of
the conditions in paragraph 25-1 for recognition of revenue from these
sales transactions (or even transactions to end-user
consumers).
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7.
|
We
note you recognize revenues from the sale of consigned inventory upon sale
of the product by the consignee. Tell us in detail how you are
able to determine the sales of the product by the consignee and why you
believe such information is reliable in light of the ability of your
customers to return items to you. Provide us with your detailed
analysis of Question 2 of ASC
605-10-S99-1.
|
Accounts
Receivable
|
$10,000
|
|
Music
Sales
|
$10,000
|
|
To
record music sales from consignment as reported by consignee for
January.
|
||
Cost
of Goods Sold
|
$5,000
|
|
Inventory
|
$5,000
|
|
To
record cost of sales on consignment sales as reported by consignee for
January.
|
||
Accrued
Sales Returns
|
$2,000
|
|
Deferred
Gross Profit on Estimated Returns
|
$2,000
|
|
To
accrue sales for estimated consignee returns on January
sales.
|
||
Deferred
Gross Profit on Estimated Returns
|
$1,000
|
|
Cost
of Goods – Accrued Sales Returns
|
$1,000
|
|
To
accrue cost of sales for estimated consignee returns for January
sales.
|
||
Deferred
Gross Profit on Estimated Returns
|
$1,000
|
|
Accounts
Receivable
|
$1,000
|
|
To
record credit memo for consignee returns reported in
January.
|
||
Inventory
|
$500
|
|
Deferred
Gross Profit on Estimated Returns
|
$500
|
8.
|
We
note your response to comment four from our letter dated November 17,
2010. Please revise the line item titled “customer credits on
account” to more appropriately label as “warranty provisions”. Also,
please provide the information required by 50-8 of ASC 460-10-50 for your
warranties and other guarantee
contracts.
|
Fiscal
Year Ended
|
||||||||
March
31,
|
March
31,
|
|||||||
2010
|
2009
|
|||||||
Estimated
return and allowance liabilities at beginning of period
|
$ | 288,039 | $ | 217,812 | ||||
Costs
accrued for new estimated returns and allowances
|
727,534 | 570,661 | ||||||
Return
and allowance obligations honored
|
(891,865 | ) | (500,434 | ) | ||||
Estimated
return and allowance liabilities at end of period
|
$ | 123,708 | $ | 288,039 |
9.
|
Further,
it is unclear to us why you believe you have the right of offset or
represent that such amounts “will be offset with new merchandise invoices
in the upcoming season” since your customer has no legal obligation to
continue purchasing from you. Refer to ASC
210-20-45. Further, tell us why you believe it is appropriate
under any accounting literature to offset credit balances with new
merchandise invoices in the upcoming season (i.e. future periods), or are
you solely referring to your business arrangement with some of these
larger customers. Describe your accounting for these
arrangements/transactions and provide journal entries that detail your
accounting.
|
Accounts
Receivable
|
$100,000
|
|
Customer
credits on account
|
$100,000
|
|
To
reclassify all customers’ credit balances in Accounts Receivable to
current liabilities.
|
||
Customer
credits on account
|
$50,000
|
|
Accounts
Payable
|
$50,000
|
10.
|
We
note your response to comment six from our letter dated November 17,
2010. Please expand your disclosure here, in liquidity and in
other appropriate sections of your filing to disclose your response
regarding the ability of your parent, The Starlight Group, to provide the
bridge financing in light of the withdrawal of your bank’s factoring and
credit facilities.
|
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