Subject: File No. JOBS Act Title III
From: Daniel F Zahlis
Affiliation: Founder Product Architect Active Agenda LLC

January 29, 2014

I have remained determined to create an innovative software tool to manage risk for nearly two decades.

I have encountered multiple starts and stops along the way. The single most debilitating factor in my "failures" has been the destabilizing practice of setting valuations before a venture can accurately define or justify value. Ventures often fail when valuations become the primary focus of the venture and a destructive source of contention between stakeholders.

Please consider a set of dynamic equity standards in your recommendations. Dynamic equity standards can align stated value with actual value and instill fairness for everyone involved.