Subject: File No. S7-38-04
From: Marvin Lutz

January 10, 2005

As a buy-side analyst working for an insurance company’s investment arm, I would like to point out in the strongest terms possible that requiring the filing of internet roadshow Powerpoint slides is likely to result in a significant reduction in the information available to qualified institutional investors. In turn, this will raise the cost of capital for issuers as well as eliminate a very useful tool (the internet roadshow capability) in which we have an opportunity to receive “almost live” information. Since not all roadshows can possibly come to every venue, this capability is critical to ensuring the widest possible distribution of information. The internet roadshow format also allows for maximum flexibility for analysts and portfolio managers, who universally have busy schedules and may not be able to attend even a large fraction of all relevant roadshows in person.

Thanks you for considering my position.

Marvin Lutz
Senior High-Yield Analyst
Allstate Investments, LLC
3075 Sanders Road, Suite G3A
Northbrook, IL 60062
(847) 402-1652