April 5, 2006
Securities and Exchange Commission
100 F. Street NE
Washington, D.C, 20549-9303
To Whom It May Concern:
I work for a Top 10 Internet property, that is heavily involved with online reporting on what is new on the internet. I take exception to your contention that there is an easily available resource on the internet for the Performance Graph now presented in the executive compensation section of the proxy. This is not the case. While there are many sources of charts on the internet none offer the total return figures found on the graph in the proxy.
While you certainly may be excused for not being aware of this, the thing I find most remarkable about this suggestion is that a regulatory agency is suggesting investors use the vast free-for-all called the internet for up-to-date financial information. As an investor and internet professional, there are several concerns about using the internet that bother me. Certainly the internet has much to offer, but there are nuances you must consider , especially with regards to financial data.
The first is data synchronicity. There is virtually no chance the information gathered on the internet by a random group of investors is going to be the same. Various sites present data in various ways and virtually no two are alike. This would appear to be a problem as no two investors are necessarily going to be getting the same thing even when they think they are. And this information once acquired is not likely to match that in the proxy. The chance for comparing apples to oranges is virtually guaranteed. How can investors make coherent decisions when each is potentially looking a different set of facts?
The second is consistency. Because the internet is unregulated there are no standards for updates or refreshes on information. Data can change overnight and does. What an investor sees Monday may not be there Tuesday. This is irritating for the user but from a regulatory point of view, having data that disappears could pose a problem.
The third is reliability. There are no guarantees on financial information taken from the internet. Even after joining a reputable site, the disclaimers investors must agree to as a term of use, insure that even in the event the information presented is wrong there is no recourse.
There are certainly reputable sites on the internet like Hoovers, SP, or Reuters there is little for free unless you join and become a member. EDGAR is a great site. I am not sure why after making an investment in a stock I need to be forced into using these in order to vote my proxy.