Subject: File No. 265-25-05
From: Henry J Russo

June 2, 2010

Opinion on Reverse Stock Splits:

Because the stock is generally at a low (usually very low) point when the reverse is made, the potential value increase is reduced by the percentage of the reverse multiplier. 10 shares, that were once 100, now have to increase by 10x's to obtain the same gain. To be fair the losses are the same. However, the fact that an increase is the objective, and anything else would equate to failure, a reverse split is clearly a major negative return for the shareholder. It constitutes nothing more than a snare. It should be an SEC and/or FTC violation to maintain a permanent reverse split, and a reasonable time limit should be imposed.