From: Gianna La Rana [Gianna_LaRana@saes-group.com]
Sent: Thursday, May 23, 2002 10:27 AM
To: rule-comments@sec.gov
Subject: File No. S7-08-02 - Saes Getters' comments on SEC proposal

Dear Sirs,

further to the comments required on the SEC proposal on periodic reporting (Release No.
8089 April 12, 2002), our opinion is the following.
We would like to first point out that, for the time being, the proposal would not apply to
our company, as it is a foreign issuer.
If the proposal to accelerate filing deadlines for domestic companies' annual report would
concern Form 20F in the future, we think it could be feasible for us to reduce by 30 days
the current deadline (accelerating to five months from the current six after the end of
the fiscal year covered by the report). This because our usual practice, so far, is to
file the Form 20F immediately after the ordinary shareholders' annual meeting (which under
Italian law has to be held within 4 months as of the year end).
With regards to the quarterly reports, if any obligation to file such report was
established for foreign issuers as well, in our experience accelerating to 30 days from 45
days (same deadline currently required under Italian regulation) would be feasible for the
second and third quarters but it would cause a non negligible increase in costs and
workload. Instead, accelerating to 30 days from 45 days would not be feasible for the
first quarter, since it would imply a risk of overlapping with the annual financial
statements to be approved by shareholders, which we would like to avoid. Accelerating the
deadline for the filing of the fourth quarter report would not be feasible as well, since
there would not be sufficient time to complete the auditor review and moreover the
workload in this period is usually already high in view of the administrative accounting
procedures required by the year end.
As per the SEC proposal that companies simoultaneously post all documents filed with SEC
on their web site, we support it, since it would assure transparent and prompt information
to the financial market. It is to be said that under Italian applicable regulation, our
company (as it joined the STAR market segment*) is already required to post all the
financial reports (together with any other documentation which may be significant to the
financial community) on its web site the day of their filing with Borsa Italiana S.p.A.
(the Italian administrative body which regulates certain technical requirements and
trading rules).
At disposal for further clarifications,

Gianna La Rana

_______________________
Gianna La Rana
Investor Relations Manager
SAES Getters S.p.A.
Tel. +39 02 93178 273
Fax +39 02 93178 370
E-mail gianna_la_rana@saes-group.com

  *   STAR  (Segmento  Titoli con Alti Requisiti) is the new market segment of the Mercato
Telematico  Azionario  of  the  Borsa  Italiana  S.p.A.  reserved  for  small  and  medium
capitalization  companies operating successfully in the traditional sectors of the economy
and  meeting  stricter  and  more  specific  requirements  with  respect  to transparency,
liquidity and corporate governance.