From: Mike Liles, Jr. [MLiles@karrtuttle.com]
Sent: Thursday, September 26, 2002 1:25 PM
To: rule-comments@sec.gov
Cc: asc@asc.state.al.us; rg@nasaa.org; mb@nasaa.org
Subject: Release Nos. 33-8119; 34-46301; File No. S7-30-02

These comments are those of the Corporate Finance Practice Group of this 
law firm, Karr Tuttle Campbell, 1201 Third Avenue, Suite 2900, Seattle, 
Washington 98101.  We realize that the comment deadline has passed but 
nevertheless submit these comments in support of the views expressed in 
the letter to you on the above subject dated September 23, 2002 by 
Joseph Borg on behalf of the North American Securities Administrators 
Association.  We concur with the views expressed in Mr. Borg's letter and 
in addition to the authorities cited by Mr. Borg note that the U.S. Supreme 
Court recently held in The Wharf (Holdings) Limited v. United International 
Holdings, 121 S. Ct. 1776 (2002) that an oral statement made with a secret 
reservation that renders it inaccurate if made in connection with the 
purchase or sale of a security can support an action under Section 10(b) 
of the Securities Exchange Act of 1934 and Rule 10b-5 thereunder.  We see
no reason why this principle does not apply to all who intentionally mislead 
investors with statements for which they harbor secret reservations, whether 
they be investment bankers, securities traders, heads of brokerage firms or 
the research analysts that are the subject of the above proposal.

Respectfully submitted,
Mike Liles, Jr.