V. I. Technologies, Inc.
134 Coolidge Avenue, Watertown, MA 02472
May 23, 2002
Jonathan G. Katz
Securities and Exchange Commission
450 Fifth Street, NW
Washington, DC 20549
|Re:||File No. S7-08-02 Acceleration of Periodic Report Filing Dates and Disclosure|
Concerning Website Access to Reports
As a company that would be affected by SEC rule changes, we would like to comment on your proposal contained in File No. S7-08-02.
Acceleration of Filing Dates
We agree that financial information used in making investment decisions is most useful when the information is made available in a timely manner. Your proposal to shorten the time period for submission of financial reports to the SEC moves the reporting process in the right direction. We feel that your proposed reporting dates are appropriate and your implementation timetable is acceptable
From our perspective, we have the internal capability to meet the proposed dates. Our only concern is scheduling the time of our independent accountants and lawyers to perform their reviews which should be manageable. This, of course, will become much more of a challenge as all public companies attempt to implement the same accelerated schedule.
Website Access and Disclosure
We currently provide a hyperlink from our website to the SEC Edgar site to provide interested parties with access to our complete SEC filings. While we recognize that there could be a delay of 24 to 48 hours between the time of our filing and the time of a report's availability on Edgar, we feel that this is a reasonable and timely method of providing access. At this time, we do not believe posting the complete SEC filings to our website is necessary.
Thank you for your consideration of our comments.
Thomas T. Higgins
Executive Vice President,
Operations and CFO