November 28, 2007
Concept Release No. 33-8860 advises that "the Commission's staff, when reviewing disclosure related to business activities in or with a State Sponsor of Terrorism, interprets materiality in the same way it does when reviewing disclosure relating to any other corporate activities not covered by a specific rule or regulation." We do not believe the materiality filter satisfies the investing public's expressed desire for information. Specifically, we urge the Commission to amend disclosure rules (Part 1A risk factors section of 10-K, to comply with risk factors described in item 503(c) of Regulation S-K)to require disclosure of all activities (including nature of activities and amount of revenue) in or with countries designated as State Sponsors of Terrorism by the U.S. Secretary of State.