Subject: File No. S7-18-09
From: John R Dempsey
Affiliation: Former Value Line Mutual Fund Manager

August 8, 2009

In June 2005, I was the Chief Quantitative Strategist for Value Line, Inc. I also managed three publicly traded mutual funds with assets in excess of $700MM. Because of my deep concerns over transaction fees, 12b-1 fees and comments made by senior management like "all these politicians want their cut", I contacted the SEC. I applaud the SEC and the NYS Attorney General for your efforts to stop the "pay-to-play' practice which only serves to undermine the public trust in investment advisors and regulators.