Subject: File No. S7-28-04
From: Phil Brown
Affiliation: CEO, Global Securities Information, Inc.

October 15, 2004

Global Securities Information
419 Seventh Street, N.W.
Washington, D.C. 20004

By e-mail rule comments

Jonathan Katz
Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549-0609

Re: File No. S7-28-04
Press release No. 2004-89
Press Release: Release of Comment Letters and Responses

Dear Mr. Katz,

This letter responds to the above captioned press release in which the Securities and Exchange Commission the Commission solicited comments regarding its decision to post staff comment letters and filer responses on its EDGAR system.
Global Securities Information GSI is happy to respond to the press release issued on June 24th 2004. Our SEC Staff Review database SSR provides access to the most comprehensive collection of staff comments and issuer responses through our online platform, LIVEDGAR. These staff comments and issuer responses, previously unavailable online with a single search interface, afford an unprecedented view of the many interactions between the Commission and the reporting community. Our customers, attorneys in AMLAW 200 law firms, accountants in major accounting firms and executives with Fortune 500 corporations use the SSR to gain invaluable insight to aid them in preparing best practices disclosures and more effectively respond to staff comments they receive. We developed the SSR in response to requests from our customers.
Our initiative to create and pay for 8,000+ FOIAs to date our SSR database has substantially reduced the time and costs associated with obtaining copies of staff comments and issuer responses, for all persons. According to the Commissions 2003 Annual Report, a FOIA request for a typical letter would take 152 days Median to become available and would cost approximately 30.00 in FOIA fees. A person making a request would also incur the time in correctly identifying a company that has been subject to review the Commission does not disclose this information and in preparing the written request. In contrast, our customers have immediate access to the letters and pay about 70 less than just the direct costs of a FOIA they submit themselves.
As the trailblazer in providing widely available transparency to the Commissions review process, GSI applauds the Commissions decision to publicly release all staff review correspondence. The investing public and analysts will benefit from the availability of staff comments and issuer responses regarding companies they invest in and cover.
Following are our questions about the process relating to the release of staff comments and filer responses:
1 Historically, the Commission has never added new forms or additional requirements to the EDGAR filing system without a formal rulemaking process. The release of the staff comments and filer responses represent a change from this precedent. Is the Commission changing the scope of its rulemaking process?

2 We are concerned that the transparency expected from the release of all comment letters and filer responses will be severely diminished due to an expected increase in the number of Rule 83 confidential treatment requests, the filing of substantive responses to comments within supplementary materials and communication of substantive responses by telephone. We believe that without a formal rulemaking process to clarify these rules or strict adherence to existing rules of practice by Commission staff that circumvention will be the rule.

3 Is there any move by the Commission to make all material that has been requested through the FOIA process publicly available. This would follow the Commissions reasoning with regard to transparency and free of charge goals.
4 Will the Commission staff be making a determination on the validity of all confidential treatment requests it receives as part of each review it conducts? Or will the Commission wait for a FOIA request to be filed for every redacted filer response released?

5 Will the Commission be releasing comment and response letters to all disclosure filings that are selected for review?

6 GSI currently has over 6000 pending FOIA requests for comment and response letters relating to completed reviews. We assume that these requests will be processed by the FOIA office and CF according to existing FOIA rules. Please confirm.

Best Regards

Phil Brown
Global Securities Information, Inc.
FROM: Phil Brown