Subject: File No. 4-564
From: Tim L Hipp
Affiliation: President, Wellness Solutions

October 13, 2008

In the American context, where we have dispersed ownership, we need conservative accounting rules that are comparable across companies. The proposed move from US GAAP to IFRS is a step backward. Please do not sacrifice our relatively good accounting standards for something less accurate and applicable to the needs of our nation and its securities markets.