Subject: File No. S7-25-06
From: James C Steele

January 31, 2007

It is hard to believe that a net worth value (and an increased value is proposed) is used to identify "such persons who are capable of evaluating the merits and risks of an investment in private offerings may invest in one" (p.17). According to that criteria, a recent PhD graduate in investment theory is less qualified than a 90 year old widow whose husband always looked after the investments.

Not only does this seem specious but it is not keeping with the American value of a level playing field.