Subject: File No. JOBS Act Title III
From: Rod Turner
Affiliation: CEO and Founder, CrowdFunding business

June 12, 2012

Thank you for encouraging comments.

I have been an entrepreneur since 1982, when I joined a startup called Ashton Tate, maker of dBASE. I was part of the team that raised venture capital from Kleiner Perkins Caufield and Byers to launch Symantec, and went on to help build this company into a sizable success. I have worked with and raised capital from some of the most respected Venture Capitalists in Silicon Valley.

I have advised, trained and lead many entrepreneurs, and have been a senior executive during two IPOs. I have raised angel capital and venture capital for numerous startups. I have made many investments myself as an angel investor (I was an angel investor in the Ask Jeeves search website, now called Ask) and made mezzanine investments in privately held technology companies.

In 2011 I founded, which is a new CrowdFunding platform that my team and I launched on May 15th 2012, I am it's CEO. I have been immersed in the CrowdFunding market for 14 months as I have developed the plan and built this startup. At supporters pledge small dollar amounts to support projects and businesses for no financial gain, we use the "all or nothing" funding model. Only projects that exceed their dollar pledge goal by their fundraising deadline are funded.

My experience puts me in a good position to understand how CrowdFunding by the sale of stock will work. I am interested in helping the SEC to create rules that will both protect investors and also encourage productive investment into worthwhile startup businesses that go on to success and to generate jobs.

One aspect of CrowdFunding that I would like to highlight for your attention is that the selection of the stage/time at which the SEC requires due diligence to be completed (and so, paid for) by the entrepreneur will have a huge impact on how many entrepreneurs will choose to raise capital through CrowdFunding. And so it can have a major positive or negative impact on how many great startups get CrowdFunded.

When an entrepreneur approaches a CrowdFunding site, he or she does not know how well accepted their startup idea, team, marketplace and presentation will be. They are not sure if their entry will be accepted by the CrowdFunding company, and if it is accepted, they do not know how many people will invest - if it will appeal to enough people to make the whole effort work.

All this uncertainty makes the entrepreneur want to find out more before having to spend time preparing due diligence and reports and paying the fees involved.

As their startup passes each milestone prior to entering fund raising, the entrepreneur becomes more confident that their startup can actually get funded, and so they become more willing to spend the money and time preparing the required due diligence, reports and to take these steps to a more comprehensive level.

At, we have introduced a new method for selection of which projects will go into funding. This process, called CrowdAudition TM, is a public forum about "candidate" projects, in which we encourage members to post advice, questions and concerns about projects. This process helps the entrepreneur to improve their presentation, their business or product idea, and gather the facts that our members suggest they need to make their presentation compelling and credible.
It helps the entrepreneur get a sense of how popular their idea/business is with the very people who might fund it. Commenting in CrowdAudition is open to the public (members can post comments, membership is free) so wide participation is possible and likely. This open approach can bring fraud or deception to the surface early, and at low cost.

A very good time to require the entrepreneur to get the reporting and due diligence work done and presented in the correct form, is as a condition that must be satisfied before their project/business will be moved from CrowdAudition into fundraising. In this way, startup businesses have been in CrowdAudition and have reached the state that they are ready and rated highly enough by members to go to fundraising, could be notified by that they will be moved to fundraising upon completing the necessary steps of reporting and Due Diligence.

I believe that if the SEC chooses to allow this type of process and sequence, it will lead to more successful startups.

While I have framed my suggestions here in the context of, I believe these issues will apply broadly to other CrowdFunding platforms,

Thank you for considering my suggestions,
Rod Turner