General Bearing Corp – ‘CORRESP’ from 10/13/04

On:  Wednesday, 10/13/04, at 1:54pm ET   ·   Private-to-Public:  Document ¶ — Delayed-and-Released:  5/13/05   ·   Accession #:  1193805-4-1575

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Delayed-and-Released Comment-Response or Other Letter to the SEC
Filing Table of Contents

Document/Exhibit                   Description                      Pages   Size 

 1: CORRESP   ¶ Correspondence Letter                                  2±     6K 


October 13, 2004                                                                

United States Securities and Exchange Commission                                
450 Fifth Street, N.W.                                                          
Washington, D.C. 20549-0510                                                     

Attn: Ms. Tracy Houser                                                          
Staff Accountant                                                                

RE: General Bearing Corporation                               
Form 8-K Item 4.01 filed October 5, 2004              
File No. 0-22053                                      

Dear Ms. Houser:                                                                

On behalf of General Bearing Corporation (the "Company"), set forth below are   
responses to your letter dated October 6, 2004.                                 

Comment # 1                                                                     

Please amend your Item 4.01, Form 8-K for the following:                        

o     The specific date Urbach Kahn & Werlin LLP resigned as your independent   
auditors, as required by Item 304 (a) (1) (i) of Regulation S-K.    

o     The two fiscal years (i.e., fiscal years ended January 3, 2004 and        
      December 28, 2002) in which you refer to in your disclosure required under
Item 304 (a) (1) (ii) of Regulation S-K.                            

o     The two fiscal years and the subsequent interim period (i.e., fiscal years
   ended January 3, 2004 and December 28, 2002 and January 4, 2004 through
    October 4, 2004) in which you refer to in your disclosure required under
Item 304 (a) (1) (iv) of Regulation S-K.                            

We have amended Form 8-K to comply with your comments.                          

Comment # 2                                                                     

To the extent that you make changes to the Form 8-K to comply with our comments,
please obtain and file an updated Exhibit 16 letter from the former accountants 
stating whether the accountant agrees with the statements made in your amended  
Form 8-K.                                                                       

We have included the updated Exhibit 16 letter from the former accountants in   
the Company's amended Form 8-K.                                                 

Closing Comments:                                                               

Pursuant to your comments, the Company acknowledges that a) it is responsible   
for the adequacy and accuracy of the disclosure filings; b) staff comments or   
changes to disclosure in response to staff comments in the filings reviewed by  
the staff do not foreclose the Commission from taking any action with respect to
the filing; and c) 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.                                           

Pursuant to your request, we will file this response letter on EDGAR.           

If you have any questions or require additional information, please call me at  
845-358-6000 or fax me at 845-358-6277.                                         

Respectfully yours,                                                             

/s/ David Gussack                                                               
-----------------------                                                         
David Gussack                                                                   
Chief Executive Officer                                                         

Dates Referenced Herein   and   Documents Incorporated by Reference

This ‘CORRESP’ Filing		Date		Other Filings
Publicly Released on:		5/13/05		UPLOAD
Filed on:		10/13/04		8-K/A
		10/6/04		UPLOAD
		10/5/04		8-K
		10/4/04		8-K,  8-K/A
		1/4/04
		1/3/04		10-K,  NT 10-K
		12/28/02		10-K,  NT 10-K
				List all Filings