Subject: File No. S7-32-04
From: Gary Bilello, CPA

September 17, 2004

I think pushing back the accelerated filing date 15 days does NOTHING

Do you really think that the extra 15 days in March 05 will help us prepare for 404 compliance which is a snap shot in time at 12/31/04. It does not help at all. No one is working on year end reporting until after year end. Everyone is buried on SOX anyway right now. If you really wanted to help and also have substance over form of getting things done try this concept.

Leave the accelerated filing date at 60 days and then push the SOX date to 3/31/05. This keeps the pressure on for the accelerated filing and also forces all the year end stuff to be done and leaves 4 more weeks to finish everything for 404. It will help build confidence in the market and economy rather then have a bunch of ugly disclosures.

You can reach me at 352-395-1346. If you want further guidance.


Gary Bilello, CPA