SEC – ‘UPLOAD’ from 10/6/04 re: General Bearing Corp – ‘LETTER’

On:  Wednesday, 10/6/04, at 10:50am ET   ·   Private-to-Public:  Document ¶ — Delayed-and-Released:  5/13/05   ·   Accession #:  0-4-32059

in

this entire Filing. an “Entity” Search.

Show

Documents searched

and

each “hit”. the 1st “hit”.

↓↑Hints

Delayed-and-Released Comment Letter from the SEC
Filing Table of Contents

Document/Exhibit                   Description                      Pages   Size 

 1: LETTER    ¶ 10/6/2004 Comment LETTER #1; Item 4.01, 8-K;           2±    11K 
                          Houser                                                 


October 6, 2004                                                                 

David L. Gussack                                                                
Chief Executive Officer                                                         
General Bearing Corporation                                                     
44 High Street                                                                  
West Nyack, New York  10994                                                     

RE:     Form 8-K Item 4.01 filed October 5, 2004                                
File # 0-22053                                                  

Dear Mr. Gussack:                                                               

We have reviewed your filing and have the following comments.  Where            
indicated, we think you should revise your document in response to              
these comments.  If you disagree, we will consider your explanation as          
to why our comment is inapplicable or a revision is unnecessary.                
Please be as detailed as necessary in your explanation.  After                  
reviewing this information, we may or may not raise additional                  
comments.                                                                       

Please understand that the purpose of our review process is to  
assist you in your compliance with the applicable disclosure                    
requirements and to enhance the overall disclosure in your filing.  We          
look forward to working with you in these respects.  We welcome any             
questions you may have about our comments or on any other aspect of             
our review.  Feel free to call us at the telephone number listed at             
the end of this letter.                                                         

1. Please amend your Item 4.01, Form 8-K for the following:                     
* The specific date Urbach Kahn & Werlin LLP resigned as your                   
independent auditors, as required by Item 304(a)(1)(i) of Regulation            
S-K.                                                                            
* 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.                                     
* 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.                            

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.                                       

*****                                                                           

Please file your supplemental response and amendment via EDGAR in               
response to these comments within 5 business days of the date of this           
letter.  Please note that if you require longer than 5 business days            
to respond, you should contact the staff immediately to request                 
additional time.  Direct any questions regarding the above to the               
undersigned at (202) 942-1989.                                                  

We urge all persons who are responsible for the accuracy and    
adequacy of the disclosure in the filings reviewed by the staff to be           
certain that they have provided all information investors require.              
Since the company and its management are in possession of all facts             
relating to a company`s disclosure, they are responsible for the                
accuracy and adequacy of the disclosures they have made.                        

 In connection with responding to our comments, please provide, in
writing, a statement from the company acknowledging that                        

* the company is responsible for the adequacy and accuracy of the               
disclosure in the filings;                                                      
* 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               
* 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.                                           

In addition, please be advised that the Division of Enforcement 
has access to all information you provide to the staff of the Division          
of Corporation Finance in our review of your filing or in response to           
our comments on your filing.                                                    

Sincerely,                                                                      

Tracey Houser                                                                   
Staff Accountant                                                                
Mr. Gussack                                                                     
General Bearing Corporation                                                     
October 6, 2004                                                                 
Page 1                                                                          

UNITED STATES                                                                   
SECURITIES AND EXCHANGE COMMISSION                                              
WASHINGTON, D.C. 20549-0510                                                     

DIVISION OF                                                       
CORPORATION FINANCE                                                             

Dates Referenced Herein   and   Documents Incorporated by Reference

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

1 Previous Filing that this Filing References

  As Of               Filer                 Filing    For·On·As Docs:Size             Issuer                      Filing Agent

10/05/04  General Bearing Corp.             8-K:4,9    10/04/04    2:7K                                     E-Data Systems, Inc./FA