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To: Harvey Kirby who wrote (7736)7/28/1998 7:53:00 AM
From: buzzlite  Read Replies (1) | Respond to of 8012
 
Heya, Harv and Gifs veterans. There's an interesting read on the sec.gov site. I believe it's the enforcement site. Just go to the search area and type in the name of your favorite trained journalist. This link might work. sec.gov.

Kinda puts one in a letter writing mood.



To: Harvey Kirby who wrote (7736)7/29/1998 3:41:00 PM
From: Harvey Kirby  Read Replies (1) | Respond to of 8012
 
Say folks,,I was cruising along in cyberspace and came across this interesting piece of information at www.sec.gov. some one told me its public information so I thought I would post it here seeing this thread has been dead now for weeks. The name of that there institute sure rings a bell......

Harvey Kirby

Investors Research Institute, Inc.
P.O. 750471, Forest Hills, NY 11375-0471
Telephone 212-484-4747, Fax 718-523-2137
E-mail: iri@pipeline.com

April 17, 1998

Via E-mail: rule-comments@sec.gov

Jonathan G. Katz,
SecretarySecurities and Exchange Commission
Mail Stop 6-9
450 Fifth Street, N.W.
Washington, D.C. 20549

Re: File Number S7-2-98

Hon. Commissioners:

On February 17, 1998 the Commission published certain proposed
amendments to Form S-8 and related rules and solicited public comments.
Release No. 33-7506.

The purpose of these comments is to address certain practical
aspects and applications of the S-8 Rulemaking process.

First, the non-profit Institute, whose missions advocated on behalf
of its small but diverse Membership include high standards for "disclosure"
and "accessibility" of information about public equities to public
shareholders and potential shareholders, was established during an
environment in which there has been insufficient guidelines for disclosure
of dilutive events, and far too many abuses of the S-8 rule whereby shares
appear to have been issued in many instances in amounts which far exceed the

monetary value of the services rendered to the issuer.

The Institute applauds the Commissioners for revisiting these
guidelines for the purpose of curing these inefficiencies of the present
rule. Public companies which enroll as Members of the Institute already
must agree to voluntarily adhere to such higher standards. Of course, the
Institute has no enforcement power nor staff to monitor abuses. It is
limited to the withdrawal of Membership privileges should a Member or the
public bring an abuse or instance of non-compliance with its standards to
its attention. And unfortunately, the investing public does not presently
have a commitment re: these "best practices in investor relations" standards

from the vast majority of public companies which have not to date adopted
the Institute's standards.

However, we would propose that the Commission move cautiously so as
not to "throw out the baby with the bath water."

More specifically, we are talking about the huge disparity between
the financial and resource-rich "blue chip" companies and the financial and
resource-poor "small capitalization" and "micro-cap" companies. In the
former instance, such companies often have entire departments devoted to
development and distributions of company information to investors and
potential investors. In the latter instance, some companies have no
assigned staff whatsoever for this purpose, and it remains in the best
interests of investors and potential investors for there to be a means by
which such companies and their investors to achieve a level of information
parity with their larger-capitalization peers.

It does not serve the investing public if such companies are left
without the necessary resources to pay for quality opportunities to present,

achieve professional scrutiny and distribute information in a timely and
enriched fashion.

Au Resivior (or something like that)