From: Murray S. Cohen
Sent: Thursday, June 16, 2005
To: acspc@SEC.GOV
Subject: Cost to acspc@sec.govsurvive under Sarbanes-Oxley

Since you are receptive to learning the difficulties imposed on a small SEC company such as Epolin, Inc , I will so inform you. We do close to $3 M in sales a year in a highly technical market. Of this we spend more than $250,000 in legal and accounting fees to meet SOX requirements. I estimate that $200,000 at least of this goes into what would not be necessary if we were a non-reporting or private company. That money could be used to increase our R&D by more than 40% which would allow us to introduce new products, improve existing products and plan for future R&D projects. Furthermore, the requirements to document expenditures like R&D expenses for time and materials is another burden taking time away from productive activities.

I think the rules are excellent for the large corporations but they are deadly for a small growing business, especially one which requires a large investment in R&D. Where the correct cut-off point should be is difficult to assess. I can see that whoever falls in the cusp will be aggrieved at the change that leaves them out of the benefits. But I feel we are so small that we are well within the group of companies that can get major benefits from relief.

Dr. Murray S. Cohen,
CEO, Epolin