Subject: File No. S7-07-12
From: Leighton Strader
Affiliation: Virginia Ventures. LLC

September 20, 2012

With regard to the prohibition for managers articulating their specific investments:
It would seem there is some middle ground to be occupied to allow investment managers to provide specific examples of securities or investments used in the formation of their overall portfolios.
Why should a prospective and qualified investor be deprived of a thorough understanding of the granular methodology a portfolio manager uses to determine and to include - or rid - an investment in his portfolio on behalf of other like investors?
Sophisiticated investors operate at a level of detail where these data are important in their analysis, and should not be penalized and kept in the dark because a few managers boast their "wins" and not their "loosers".
Why not make it required that a manager MUST have both scenarios in their materials and provide specific disclaimers as to the: precise purchase date, quantity, holding period, entry and exit price and specific profit or loss.
This is no different than showing your returns, and by prohibiting this activity you have forced investors to make decisions at a less granular level than is available. In effect, you have taken a valued "bullet" out of the investor's chamber.
Thank you,

Leighton Strader, Partner