Subject: File No. 4-573
From: Michael C Cline
Affiliation: Member AICPA

June 1, 2009

Concerning the mark to market accounting standards as described in FASB 157, it is my opinion these standard have been taken advantage of, and give rise to falsification as the market value of such assets on the balance sheets are not based on real or actual transactions conducted by the business who reports them, rather on the transactions conducted in the past by others.

Let it be known the market value of an assset is only worth the market selling price IF a transfer or sale of such asset actually occurs.

Theoretically, IF all such business who value their assets at mark to market accounting values, the shere volume of transactions would depress the market value of such prices, and as such, mark to market valuations provide only a theoretical market valuation instead of an actual or real valuation based as it is not based on any actual or real transaction or sale.

It is my opinion a businesses' ability to pay its debts to which it has committed is a better measure of a businesses health and stability, in the abscence of a bonifide appraisal or certified valuation.

In concluding my remarks I am a firm believer in the concept of a companies "book" value and allowing investors are best able to determine a company's market value as reflecdted in its stock price.