Subject: File No. S7-24-06
From: Julio J Castellanos
Affiliation: SOX auditor

June 29, 2007

I just like to give my own definition of the term Significant Deficiency, "Is the result of not having and efficient control, which results in a risk that will not be consider a risk due the fact that risk just occured. In terms if having significant control mitigating certain control objectives. To be more clear, if some fraud or loss of assets occured because a control failure that should be considered as a significant deficiency. If a control did not operate effciently or not having a control give as a consequence a fraudulent activity of a misstatement in the financial reporting in my opion should be considerer as siginicant deficiency not matter the amount of the operation.