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To: John Mansfield who wrote (22506)	8/21/1998 10:26:00 AM
From: John Mansfield	Read Replies (4) \| Respond to of 31646

New SEC rulings regarding Y2k status disclosures - now also disclosure on embedded systems demanded _____ 'A full description of a company's Year 2000 readiness will generally include, at the very least, the following three elements. First, the discussion should address both information technology ("IT") and non-IT systems. 37 Non-IT systems typically include embedded technology such as microcontrollers. 38 These types of systems are more difficult to assess and repair than IT systems. In fact, companies often have to replace non-IT systems since they cannot be repaired. To date, only a few companies have addressed non-IT issues in their disclosure. 39 We are concerned that companies are overlooking non-IT systems when they provide Year 2000 disclosure. 40 sec.gov