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Technology Stocks : VALENCE TECHNOLOGY (VLNC) -- Ignore unavailable to you. Want to Upgrade?

To: Larry Brubaker who wrote (9433)	3/15/1999 10:44:00 PM
From: Rich Wolf	Respond to of 27311

Agreed, Larry. Identical content between the last two S-3/A's. I also put them side-by-side, and found it to be as you said. I suspect the SEC has its staff review and throw back documents when they think something hasn't been clarified well enough. In this case, I would guess they wanted a summary of the lawsuits to be put up top, as well as referred to in a later section. This summary merely duplicated the comments from below. Absent that, I doubt they would have tossed it back for a rewrite. As a shareholder who appreciates the SEC's protection, this resubmission of the same content told me nothing I hadn't read last time, however. Someone from the SEC unnecessarily 'made work' for the lawyers, in this case.