Sent: Tuesday, May 21, 2002 3:04 PM 
Subject: File No. S7-08-02 
 
Mr. Jonathan G. Katz 
Secretary 
Securities and Exchange Commission 
Via rule-comments@sec.gov. 
 
Re: File No. S7-08-02 - Proposed Rule: Acceleration of Periodic 
Report Filing Dates and Disclosure Concerning Website Access to 
Reports 
 
Dear Mr. Katz: 
 
I am the CEO of EDGAR Online, (Nasdaq: EDGR), a leader in the 
business information industry, specializing in the extraction, 
packaging and distribution of public company information 
contained in SEC filings. 
 
In general we applaud the proposed changes to accelerate filing 
dates and broaden disclosure of activities that affect investors 
and the general public in gaining access to the critical 
information contained in SEC filings. 
 
However, we have several concerns with the proposed rule changes. 
These stem from our belief that the SEC's mandating electronic 
filing of important disclosure information via the EDGAR system 
has been  the key catalyst in leveling the playing field and 
providing access to the general public to information that was 
once costly and inaccessible to the average investor and to the 
general public. Effectively, in its efforts to date, the SEC has 
already made an enormous contribution in this area but, as this 
and other proposed regulatory changes demonstrate, there continue 
to be elements of public disclosure that are not transparent. Our 
overarching view is that disclosures need to be made in a timely 
fashion, they must be electronic in order to be of value to the 
public, they should be required to be filed with the EDGAR system 
and the requirements for prompt electronic disclosure of 
important information should apply equally to all public 
companies regardless of their size. If other methods of posting 
information are mandated this should not preclude the 
simultaneous submission of electronic disclosures through EDGAR. 
 
This proposal recommends accelerating the filing period only for 
companies with a public float of $75 million or more. We believe 
that ALL public companies, with the possible exception of Small 
Business filers, should have the same deadlines for filing. 
Conforming the filing dates will eliminate confusion on the part 
of the investing public.  Investors in companies with floats of 
less than $75,000 should expect the same timely access to prompt 
disclosure of information impacting their investments as 
investors in larger companies. Such prompt disclosure of 
information for smaller companies may be even more important than 
for larger companies because of the relative scarcity of 
available information on smaller public companies. 
 
We also believe that much confusion is caused in the market place 
by the common practice of issuing press releases containing 
selected earnings information in advance of making 10Q or 10K 
filings. Often the financials highlighted in the press release do 
not match the financials submitted in the next 10Q or 10K.  We 
also acknowledge the argument that requiring earlier filing of 
10Qs and 10Ks may not result in better disclosure.  As an 
alternative to your proposal of shortening the filing period for 
companies with floats in excess of $75 Million, I would like to 
propose that you consider requiring all public companies to file 
press releases containing earnings information as 8-K filings.  
Were companies required to treat earnings releases as filed 
information, they would be more careful in what was said about 
earnings prior to the release of full required disclosure in the 
10K or 10Q.  With this as the rule, companies that felt confident 
enough in their period closing to make a press release would file 
earnings information on an 8-K earlier than those companies that, 
because of more limited resources or more complex accounting 
issues, would consider an accelerated filing date for the 10Q or 
10K to be a burden.  Each company could therefore choose, within 
the existing 45 day or 90 day period, when it is ready to say 
anything publicly about its earnings.  
 
Sincerely, 
 
Susan Strausberg 
CEO 
EDGAR Online, Inc. 
50 Washington Street, 9th Floor 
Norwalk, CT 06854 
Ph: 203-852-5656 
Fax:  203-852-5667 
Email: susan@edgar-online.com 
Web:   http://www.edgar-online.com