Subject: File No. S7-06-13
From: Mark Risher
Affiliation: CEO of Startup Company

August 26, 2013

Software Startup companies raise money in a loose, ad-hoc manner, tweaking their presentation between every successive meeting, adjusting the storyline almost continually. Because seed stage companies are often defining vision, developing product, and testing the market at the same time, it is unreasonable to expect such a formal process for registering company information with the SEC prior to early-stage financing. While there is a clear need to represent information clearly to investors, this filing requirement as currently defined will prove an insurmountable burden to startup companies.