Subject: File No. S7-14-08
From: Christopher J Kirk

July 30, 2008

I am opposed to having EIA's considered as securities when they do not fit the description of a security.

This change will affect my business and my clients and possibly force my firm to change our broker dealer which will take time away from managing our clients money. I see no positive gain for making EIAs securities and I am strongly opposed to this change.

Thanks,

Chris Kirk