Subject: File No. JOBS Act Title III
From: Albert Hartman
Affiliation: CEO High Tide

June 4, 2012

The current $1M annual limit on funds in the current act is ludicrous. I'm doing a hardware consumer electronics startup. Consumer hardware is out of vogue in the current software-apps-only category that VCs are willing to fund, and is an ideal target for the JOBS act. Hardware requires purchased goods, manufacturing, shipping, high labor. $1M just is not enough to make a good difference for the documentation and compliance efforts involved. Other means are still far more practical. Irrelevance to the true needs of the startup community was not the intent of the JOBS act.

A supportive public for suitable hardware startups is willing and able to fund amounts in the $10M range as evidenced by the recently completely $10.2M Kickstarter campaign for a watch. That company is now meaningfully started - and the JOBS act wishes for more of those.

As a founder of a startup doing consumer electronics I wish to tap into this readily available public support for innovation and offer company equity as an inducement, currently barred by law but being addressed by the JOBS act. But to be useful, the $1M limit must be raised to practical levels so that it will be used for real job creation.