Subject: File No. S7-09-13
From: Robert N. Grosshandler
Affiliation: Founder,

August 7, 2014

To Whom It May Concern:

Our firm,, is a small, rapidly growing, profitable business.  We have grown our employee base 25% this year, and we expect to grow even faster over the coming months and years.

We make it possible for consumers to support their favorite charity every time they shop online, at no cost to the consumer or to the charity.  You shop.  Your charity gets money.  For free.

Over 350,000 consumers are supporting over 35,000 different charities in every state, helping them to raise much needed funds.  These charities range from local pet rescues, to thousands of schools and PTAs), and local chapters of very large nonprofits like American Lung or American Heart Association.  Over 1,500 retailers use iGive to reward their customers’ favorite charities for their shopping.

We are eager to initiate a crowdfunding campaign under the proposed Title III rules.  To that end, we have already engaged our accounting firm to audit our books, our legal firm to prepare preliminary materials, and we’ve worked with our marketing staff to be fully prepared.  We’ve held preliminary talks with an appropriate portal.  For iGive, doing a crowdfunding campaign in calendar 2014 would be ideal.

We intend to use this campaign to give our consumers and charities a stake in iGive’s future.  We don’t sell anything to consumers or to charities, so traditional, product-based crowdfunding isn’t appropriate.  We’re too small for a traditional public offering.  We’re not sexy enough for traditional venture investors.  Our consumers and charities aren’t generally accredited investors.  We believe that when non-accredited consumers and charities have a true stake in our success, our growth will accelerate dramatically.  With growth comes increased employment.  We are estimating that we would add between 20-40 full-time, U.S.-based employees and contractors to handle the increased volumes, within 12 months of funding. 

Each of the new stakeholders, having a vested interest in iGive’s success, will be in a better position to “spread the word”.  In addition, we intend to complement their activities with an increased marketing budget.

I urge you to issue final rules as soon as possible.  I’d be happy to work with staff in any helpful capacity.


Robert N. Grosshandler