Jonathan G. Katz
Securities and Exchange Commission
450 Fifth Street NW
Washington, DC 20549

Re: Comment File No. S7-13-00 - Summary of Intended Testimony

Dear Mr. Katz:

On August 25, 2000, I submitted my request to testify at the Commission's public hearing on September 13, 2000 in New York. I am currently the Executive Vice President and Chief Financial Officer of VirtualCom, Inc. Previously, I served as President and Chief Operating Officer of Autotote Corporation as well as Executive Vice President and Chief Financial Officer. Prior to my roles at Autotote, I was Executive Vice President and Chief Financial Officer of Smith Corona Corporation and Vice-President of Finance and Chief Financial Officer of General Instrument Corporation. My many years as an experienced operational and financial senior executive will shape my testimony.

In my years of experience, I have not encountered a situation where the quality of an audit or the auditor's independence was, in my judgment, compromised by the accounting firm's provision of other services. I am concerned that the SEC's proposed limits on non-audit services would eliminate a very logical and cost-effective source of quality professional services - the auditor. As a senior executive, value-added, cost-effective services from a trusted advisor are indispensable. In many cases, the audit firm is simply the best suited for a project. I anticipate addressing these concerns further in my testimony.


Thomas C. DeFazio