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Proc-Type: 2001,MIC-CLEAR
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<SEC-DOCUMENT>0001317273-05-000032.txt : 20060921
<SEC-HEADER>0001317273-05-000032.hdr.sgml : 20060921
<ACCEPTANCE-DATETIME>20050722144844
<PRIVATE-TO-PUBLIC>
ACCESSION NUMBER:		0001317273-05-000032
CONFORMED SUBMISSION TYPE:	CORRESP
PUBLIC DOCUMENT COUNT:		1
FILED AS OF DATE:		20050722

FILER:

	COMPANY DATA:	
		COMPANY CONFORMED NAME:			CCA INDUSTRIES INC
		CENTRAL INDEX KEY:			0000721447
		STANDARD INDUSTRIAL CLASSIFICATION:	PERFUMES, COSMETICS & OTHER TOILET PREPARATIONS [2844]
		IRS NUMBER:				042795439
		STATE OF INCORPORATION:			DE
		FISCAL YEAR END:			1130

	FILING VALUES:
		FORM TYPE:		CORRESP

	BUSINESS ADDRESS:	
		STREET 1:		200 MURRAY HILL PKWY
		CITY:			EAST RUTHERFORD
		STATE:			NJ
		ZIP:			07073
		BUSINESS PHONE:		2013301400

	MAIL ADDRESS:	
		STREET 1:		200 MURRAY HILL PKWY
		CITY:			EAST RUTHERFORD
		STATE:			NJ
		ZIP:			07073

	FORMER COMPANY:	
		FORMER CONFORMED NAME:	CATHETER CORP OF AMERICA
		DATE OF NAME CHANGE:	19850228
</SEC-HEADER>
<DOCUMENT>
<TYPE>CORRESP
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>





July 20, 2005

Carol Stacey
Division of Corporate Finance
US Securities and Exchange Commission
450 Fifth Street
Washington, DC 20549

Dear Ms. Stacey:

Thank you very much for your real interest in working with us to
discern our business format.  Understanding our program is vital
in reaching your determination of our ongoing financial
reporting.

I am presenting this letter as if it was a brief before the
Supreme Court.  I believe that that is the best way to make a
formal understandable presentation.

A.   1. Stipulated Facts:
      (a)  APB is the applicable section.
      (b)  93-7 does not apply to interim periods and is referenced
            back to APB 28.
     2. Neither APB 28 nor 93-7 gives an exact determination of what
        is the "clear and direct result" of advertising and "clearly
        extend" beyond the period in which the expenditures are made.
     3. It is an accepted truism that advertising does work
        subliminally.
     4. Advertising hornbooks would take the position that with a
        limited advertising budget spreading the advertising quarterly
        would not be strong enough to attract public attention and might
        not be successful.  It is not as effective as saturating a market
        in a limited time period.  With substantial funds, every
        quarter would be saturated.
     5. CCA has adopted its current advertising presentation
        consistently for 20 years. The Company has filed better than 80
        reports which have been received and accepted by the SEC.
     6. Sarbanes-Oxley requires that any financial information be
        presented fairly for shareholders to understand in a clear
        understandable manner.

B.   Issue To Be Determined
     Does Sarbanes-Oxley, or any SEC regulations recently adopted,
     require a strict construction of AICPA and take away the SEC
     determination to adopt a subjective construction of each
     individual issue depending on the particular facts?  Does the
     new SEC protocol change the SEC agenda and require that the
     SEC agenda conform strictly to the code without any leeway to
     interpret a grey area of a condition provided for in the
     AICPA?

<PAGE>

C.   Discussion of Case
     To prove a condition was the direct result of an event the
     condition had to be proven the proximate cause of the
     accident.  To prove proximate cause in numerous cases,
     statistics were deemed the proximate proof.  In tobacco cases,
     as well as the recent Vioxx incident, by analyzing the results
     of thousands of clinical participants, it was the statistics
     that led the FDA to find that tobacco or Vioxx was the
     proximate cause of the injury.  This was the only method of
     showing the "clear and direct result" of the uses of the
     products.

     The statistics set forth as "Exhibit A" prove that the sales
     in the third and fourth quarter were the "clear and direct
     result" of CCA's saturated advertising in the prior two
     quarters, the re-orders from our retail accounts.

D.   Interpretation of "Exhibit A"
     The information in the schedule set forth is the status of the
     four leading products, Mega - T, Nutra Nail, Sudden Change and
     Plus+White which account for approximately 80% of all of the
     Company's sales.  This information is broken down by quarters:
     the sales and the advertising per product per quarter.

     The last line is the summation, which clearly sets forth that
     the $24,644,832 in sales in the second half, accounting for
     48% of the year's sales of the products when only $665,148 or
     8.24% was spent on advertising during the second half of the
     year.  A similar exhibit for the prior years would show a
     similar result.

     The figures speak for themselves.  Can there be any doubt that
     the advertising saturation in the first six months was the
     proximate cause of the sales in the second six-month period
     and it clearly extended beyond the period in which the
     expenditures were made?  We believe that the data speaks for
     itself in supporting our position.

Very truly yours,



Ira W. Berman
Chairman of the Board of Directors

/js
Attachments

Cc:  Patricia Armalin
     Leslie Overton
     Nathan Chaney

<PAGE>

                             All Mega Product Lines
                        Dollars Shipped and TV Expenditures
                              2004 and Q1 2005
<TABLE>
<CAPTION>

                        Sales                              TV Expenditures
<S>              <C>            <C>            <C>     <C>           <C>            <C>
December-03      $1,047,011.66                         $       -
January-04          731,981.60                           331,453.33
February-04       1,145,395.85                           286,173.39
   Q1 2004 Total                 $2,924,389.11   17.79%               $  617,626.72  26.30%


March-04          1,632,615.49                                 -
April-04          1,912,835.79                         1,041,332.79
May-04            1,275,806.60                           487,277.00
   Q2 2004 Total                 $4,821,257.88   29.32%               $1,528,609.79  65.10%



June-04           1,597,268.10                           204,905.18
July-04           1,785,873.37                            (2,997.12)
August-04         1,551,949.81                                 -
   Q3 2004 Total                 $4,935,091.28   30.02%               $  201,908.06   8.60%


September-04      1,124,066.16                                 -
October-04          547,526.75                              (106.25)
November-04       2,088,550.05                                90.67
   Q4 2004 Total                 $3,760,142.96   22.87%               $      (15.58)  0.00%


2004 TOTAL                      $16,440,881,23  100.00%               $2,348,128.99 100.00%




December-04       1,467,153.36                            16,930.65
January-05        1,789,289.02                           354,568.11
February-05       2,108,311.70                           180,489.56
   Q1 2005 Total                 $5,364,754.08                        $  551,988.32

</TABLE>


                               Exhibit A

<PAGE>
                        All Nutra Product Lines
                 Dollars Shipped and TV Expenditures
                          2004 and Q1 2005
<TABLE>
<CAPTION>



                   Sales                                  TV Expenditures
<S>             <C>         <C>           <C>       <C>         <C>            <C>
December-03      365,181.87                            5,620.52
January-04       657,388.08                          598,596.33
February-04      568,736.67                          564,503.97
   Q1 2004 Total            $1,591,306.62   24.87%              $1,168,720.82   63.49%


March-04         843,918.46                           (7,512.83)
April-04         860,448.99                          324,193.20
May-04           610,461.27                          370,775.25
   Q2 2004 Total            $2,314,828.72   36.17%              $  687,455.62   37.35%



June-04          453,006.54                           (3,503.72)
July-04          436,194.13                            5,239.60
August-04        547,737.23                          (24,499.82)
   Q3 2004 Total            $1,436,937.90   22.45%              $  (22,763.94)  -1.24%



September-04     361,965.78                            7,301.25
October-04       333,313.95                             (106.25)
November-04      360,874.57                               90.37
   Q4 2004 Total             $1,056,154.30  16.50%              $    7,285.37    0.40%

2004 TOTAL                   $6,399,227.54 100.00%              $1,840,697.87  100.00%


December-04      358,431.73                            4,641.00
January-05       391,071.02                          327,691.46
February-05      548,536.91                          136,005.48
   Q1 2005 Total             $1,298,039.66                      $  468,337.94

</TABLE>

                                         Exhibit B
<PAGE>
                    All Sudden Change Product Lines
                Dollars Shipped and TV Expenditures
                         2004 and Q1 2005
<TABLE>
<CAPTION>

                        Sales                                TV Expenditures
<S>               <C>            <C>           <C>      <C>         <C>           <C>
December-03          471,506.63                            5,742.60
January-04           734,875.29                          331,658.19
February-04        1,257,679.81                          367,464.54
    Q1 2004 Total                 $2,464,061.73  19.47%              $ 704,865.33   57.81%


March-04            1,498,287.59                                -
April-04            1,192,495.01                         198,553.28
May-04              1,096,217.32                                -
    Q2 2004 Total                 $3,786,999.92  29.93%              $ 198,553.28   16.28%



June-04             1,133,941.60                          (2,150.55)
July-04             1,236,786.43                                -
August-04           1,362,983.74                                -
    Q3 2004 Total                 $3,733,711.77  29.51%              $  (2,150.55)  -0.18%



September-04          859,215.89                         317,978.73
October-04            629,064.33                                -
November-04         1,181,207.61                                -
    Q4 2004 Total                 $2,669,487.83  21.10%              $ 317,978.73   26.08%


2004 TOTAL                       $12,654,261.25 100.00%             $1,219,246.79  100.00%



December-04           410,780.25                           3,965.25
January-05            778,089.86                         343,467.62
February-05           765,624.98                         114,489.21
    Q1 2005 Total                 $1,954,495.09                     $  461,922.08

</TABLE>
                                            Exhibit C

<PAGE>

                All Plus White Product Lines
             Dollars Shipped and TV Expenditures
                      2004 and Q1 2005
<TABLE>
<CAPTION>

                              Sales                                   TV Expenditures
<S>                      <C>           <C>             <C>      <C>          <C>             <C>
December-03                 923,007.53                              7,765.35
January-04                1,740,851.98                            674,559.40
February-04               1,541,030.42                            703,332.99
    Q1 2004 Total                       $4,204,889.93    27.23%               $1,385,657.74    55.51%


March-04                  1,518,024.29                            (11,082.94)
April-04                  1,439,307.53                            965,475.68
May-04                    1,225,391.75                              7,080.57
    Q2 2004 Total                       $4,182,723.57    27.09%               $  961,473.31    38.52%



June-04                   1,026,295.41                             (5,194.92)
July-04                   1,301,409.76                            158,857.90
August-04                 1,415,206.64                                   -
    Q3 2004 Total                       $3,742,911.81    24.24%               $  153,662.98     6.16%



September-04              1,150,194.23                             (4,741.28)
October-04                1,007,854.78                               (106.25)
November-04               1,152,345.45                                 90.67
    Q4 2004 Total                       $3,310,394.46    21.44%               $   (4,756.86)   -0.19%


2004 TOTAL                             $15,440,919.77   100.00%               $2,496,037.17   100.00%



December-04                 911,048.44                              4,402.82
January-05                1,058,048.00                            298,817.16
February-05                 886,777.93                             71,997.49
    Q1 2005 Total                       $2,855,874.37                         $  375,217.47

</TABLE>
                                             Exhibit D
<PAGE>


                       CCA INDUSTRIES, INC.
                 SALES AND ADVERTISING SCHEDULE
             FOR FISCAL YEAR ENDED NOVEMBER 30, 2004
<TABLE>
<CAPTION>


        BRAND           Q   NET SALES             ADVERTISING
<S>                   <C><C>            <C>      <C>           <C>
 MEGA                  Q1 $2,924,389.11  17.79%  $  617,626.72  26.30%
                       Q2  4,821,257.88  29.32% # 1,528,609.79  65.10%
                       Q3  4,935,091.28  30.02% #   201,908.06   8.60%
                       Q4  3,760,142.96  22.87% #       (15.58)  0.00%
 MEGA TOTAL:             $16,440,881.23          $2,348,128.99

 NUTRA NAIL            Q1 $1,591,306.62  24.87%  $1,168,720.82  63.49%
                       Q2  2,314,828.72  36.17%     687,455.62  37.35%
                       Q3  1,436,937.90  22.45%     (22,763.94) -1.24%
                       Q4  1,056,154.30  16.50%       7,285.37   0.40%

 NUTRA NAIL TOTAL:        $6,399,227.54          $1,840,697.87

 SUDDEN CHANGE         Q1 $2,464,061.73  19.47%    $704,865.33  57.81%
                       Q2  3,786,999.92  29.93% ##  198,553.28  16.28%
                       Q3  3,733,711.77  29.51% ##   (2,150.55) -0.18%
                       Q4    669,487.83  21.10% ##  317,978.73  26.08%

 SUDDEN CHANGE TOTAL:    $12,654,261.25          $1,219,246.79

 PLUS WHITE            Q1 $4,204,889.93  27.23%  $1,385,657.74   55.51%
                       Q2  4,182,723.57  27.09% #   961,473.31   38.52%
                       Q3  3,742,911.81  24.24%     153,662.98    6.16%
                       Q4  3,310,394.46  21.44%      (4,756.86)  -0.19%

 PLUS WHITE TOTAL:       $15,440,919.77          $2,496,037.17



 TOTAL QUARTER ONE       $11,184,647.39  21.96%  $3,876,870.61   49.05%
 TOTAL QUARTER TWO       $15,105,810.09  29.66%  $3,376,092.00   42.71%
 FIRST HALF TOTAL:       $26,290,457.48  51.62%  $7,252,962.61   91.76%


 TOTAL QUARTER THREE     $13,848,652.76  27.19%  $  330,656.55    4.18%
 TOTAL QUARTER FOUR      $10,796,179.55  21.20%  $  320,491.66    4.05%
 SECOND HALF TOTAL:      $24,644,832.31  48.38%  $  651,148.21    8.24%

 TOTAL YEAR 2004:        $50,935,289.79 100.00%  $7,904,110.82  100.00%
</TABLE>

<PAGE>
</TEXT>
</DOCUMENT>
</SEC-DOCUMENT>
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