From: Jay Brooke [jbrooke@gsionline.com] Sent: Tuesday, May 07, 2002 10:29 AM To: rule-comments@sec.gov Cc: herouxr@sec.gov Subject: Public Comment Letter re: File No. S7-08-02 May 7, 2002 Jonathan G. Katz Secretary U.S. Securities and Exchange Commission 450 Fifth Street, NW Washington, DC 20549-0609 RE: SEC Release No. 34-45741, File No. S7-08-02 Lifting the 24-hour Delay on Filings Posted to SEC.gov Dear Mr. Katz, Global Securities Information, Inc. ("GSI") is a leading provider of public-record business transaction information to law and accounting firms, investment banks, corporations, and the business press and a level one subscriber of the Securities and Exchange Commission ("Commission") EDGAR feed via the Commission's contractor, TRW. GSI feels compelled to comment on the Commission's proposed rule relating to the "Acceleration of Periodic Report Filing Dates and Disclosure Concerning Website Access to Reports". Specifically, GSI would like to comment on the Commission's stance related to the timeliness of filings whereby the Commission declares "...we anticipate eliminating this 24-hour delay for filings posted to our website, thus providing real-time posting of disseminated filings." GSI has several concerns. First, the Commission appears to be linking the issues of timely financial reporting by companies and removing the 24-hour delay for filings on SEC.gov. In GSI's opinion, the two are completely separate issues and should be addressed as such with an appropriate period for comment and feedback from the public and the level one subscribers. Second, in taking this unilateral action, the Commission will unwittingly greatly devalue the level one feed by competing with the Commission's level one feed customers it has sought to serve in the past. Normally, substantial devaluation of any product, in this case the Commission injecting itself as a competitor, results in a commensurate reduction in price. What level of price reduction in the level one feed can level one subscribers expect from the Commission's contractor as a result of this devaluation? Third, given that the rationale for allowing EDGAR Online an exclusive arrangement on the SEC.gov web site was to provide the public with a "free" source of live filings, at what point will this exclusive arrangement be terminated with the lifting of the 24-hour delay? As we stated in previous letters of comment, EDGAR Online's service provided by a link from sec.gov is not "free" as evidenced by the approximately $8 million increase in Edgar-Online's market capitalization after releasing a press release saying they had an arrangement with the Commission. Nor is it "free" due to EDGAR Online's cross selling of its subscription services and their enrichment from paid advertising placed on the site. Finally, this would represent a major change in the Commission's current contract with its vendor. Based on this substantial change, and assumed additional cost, will the SEC put out a Request For Proposal ("RFP") allowing for a rebid of the contract based on the new requirements? Should this be the case, as we expect, GSI would like our name added to the RFP solicitation list. Thank you for your consideration of GSI's views on these very important matters. If you have any further questions or comments on this matter, or GSI's views, please do not hesitate to contact me at (202) 628-1155 or by email at pbrown@gsionline.com. Sincerely, Phil Brown CEO Global Securities Information, Inc.