Subject: File No. 3-11590
From: William Turnbull

June 18, 2007

I was shocked and disgusted to see that over 90% of all individual investors will receive nothing from this settlement due to the arbitrary "de minimus" threshold. This new invention has no precedent in my dealing with Janus. Janus routinely distributed smaller amounts, and calculated amounts to fractions of a cent then rounded to the penny. Clearly Janus has the processes in place to efficiently distribute small amounts of funds and has done so routinely in the past. Furthermore, had Janus not indulged in the activity subject to the settlement, small investors would have received the full amount of the funds due them.

I recommend a de minimus penalty of $1. This would result in only a few hundred thousand shareholders receiving more than owed and would consume less than 2% of the total civil penalty - a far more equitable result than denying restitution to over 90% of the aggrieved shareholders.