Subject: File No. S7-38-04
From: David Tuttle
Affiliation:

David Tuttle
2122 8th Ave N #403
Seattle, WA 98109
tuttled@seattleu.edu

Daniel Horwood
Division of Corporate Finance, Securities and Exchange Commission
450 Fifth St, NW.
Washington D.C. 20549-0402

Dear Mr. Horwood:

I am writing to request an extension to file a comment on the proposed rule entitled "Securities Offering Reform," SEC file # S7-38-04. In particular, my comment will address the liability issues raised in Section IV of the proposed rule.

Section IV of the proposed rule is technical in nature, and it will take additional time to gather and analyze the relevant information, such as judicial opinions, scholarly articles, and professional input that bear on the issue.

My request is made perhaps more pertinent by the lack of comprehensive comments in the docket as of January 26, 2005. An extension it would make it possible for additional interested persons to file comments of a substantial nature.

Thank you for your consideration,

Sincerely,

David Tuttle

Cc: Jeffrey Cox