From: Eric Benhamou [Eric.Benhamou@corp.palm.com]
Sent: Friday, May 17, 2002 6:32 PM
To: 'Walker.Bass@nasdaq.com'; 'rule-comments@sec.gov'
Subject: File No. S7-09-02

I find the 2-day reporting delay to be overly stringent. Three types of
communications need to happen within that time frame:
- a broker must notify his client (Sec-16b officer) that an order (stock
transaction) has been completed.
- the client must notify the department responsible for stock administration
and reporting that the transaction has been completed.
- the stock administration and reporting department must file a report

If the three communications each take 1 day, the 2-day budget is exceeded.
The fact that the three parties are often in different time zones, sometimes
even different countries, complicate the matter further. I would recommend a
more lenient 3 or 4 day delay requirement.

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Eric Benhamou
Chairman, Palm Inc.
T. (408) 878-2757
F. (408) 878-2910
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