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To: Starlight who wrote (18996)2/8/2001 8:36:43 PM
From: Art Bechhoefer  Respond to of 60323
 
Betty, you're right that companies are reluctant to give out information to individuals, which is not also available to the general public. Regulation FD, I believe, applies mainly to information with an impact on future earnings, not to information that has already been factored into prior earnings. Thus, the information on royalty sources is being requested simply in greater detail than had been shown in the earnings statement. I wouldn't be surprised if it is provided in the 10K, whenever that is filed.

In other words, if the information requested is, or should have been part of that which the company is required to disclose for prior periods, then there should be little if any reason to refuse to provide that information. Regulation FD is intended to prevent a company from giving private opinions on how good its business prospects are to selected analysts or firms. I would definitely put up a fight if a company declined to provide details of past quarterly or annual performance, as opposed to future performance.

Art