From: Steve Lanza [email@example.com]
Sent: Monday, April 29, 2002 2:25 PM
Cc: Steve(NMGC) Lanza
Subject: S7-08-02 comments
The Securities and Exchange Commission
Office of Investor Education and Assistance
450 Fifth Street, NW
Washington D.C. 20549
NeoMagic is a public semiconductor company based in Silicon Valley. Like so many others, we are under extreme price and technology pressures. This requires us to continually streamline our non-development related expenses. Under the current proposal S7-08-02 we see some benefits to our shareholders but also costs. Below are our comments:
Acceleration of Periodic Report Filing Dates and Disclosure Concerning Website Access to Reports
We highly support and currently follow the SEC's recommendation to utilize our website to provide information freely to our shareholders. This includes our SEC filings. We however HIGHLY DISAGREE WITH REDUCING THE AMOUNT OF TIME TO PROVIDE OUR QUARTERLY AND ANNUAL FILINGS.
We like so many other small companies have very limited financial staffs. To meet this requirement we would have to increase our accounting staff by 20%. We also believe by adding this additional time pressure, the quality of the reporting will actually decrease rather than increase for most companies.
Current reports on Form 8-K for a number of specified events
We support the use of Form 8-K filings to improve reporting and in particular support the idea of reducing the timing window for S-8 filings. We however believe the 2 day window relative to loan/equity transactions is too short. We agree that the current timing is too long, we suggest a timeframe more in the middle. Our suggestion is to require the filing within 30 days.
As a member of the financial community, FEI member, AEA member, Fabless Semiconductor Association member and a Certified Management Accountant I hope you will take these thoughts into consideration in reviewing your proposal.
Vice President, Operations & Finance
Chief Financial Officer
3250 Jay Street, Santa Clara Ca. 95054
Phone (408) 486-3879 Fax (408) 654-6167