Subject: File No. s7-03-17
From: Laurie A Pergamit

May 2, 2017

(1) There is a claim that in-line will reduce filing preparation time.
While HTML and XBRL are combined in one document, the HTML and XBRL preparation work is separate and distinct. There is no reduction in preparation time, as different criteria and review applies to both pieces.

(2) A better chance for lack of binary concentration
With conflicting goals of both XBRL and HTML in one document, the reviewer is more apt to lose focus in the combined document rather than concentrating on either the HTML or the XBRL in a binary fashion. It may be easier for a casual user of a combined document to sneak a peek at the HTML underlying an element, but a casual user is not tasked with input and construction of the document. Construction of the HTML is dependent on understanding and applying GAAP and SEC requirements with Company-specific knowledge. Construction of the XBRL is dependent on applying the FASB taxonomy and related architecture. The tasks and skills involved with both constructs are separate and distinct. A design that merges the two disregards these construct parameters and creates a possibly unwieldy mega document that may be quite difficult to construct and perform detail reviews in a binary manner.

(3) Technological advance.
There are claims that in-line is a technological advance. There is a great deal of 'shiny newness' associated with in-line XBRL however given the constraints creating, reviewing and integrating a unwieldy mega document, the technological advance is similar to an old-fashion LED wristwatch where the user had to 'push a button' to see the time. Yes a technological advance, but rather than offering up benefits, the user or the creator of the document suffers more work and confusion in using in-line.

(4) How used.
Before claiming that we need to rush off and have in-line because the UK has it, the SEC needs to provide concrete examples of information tools that investors use to data mine the current XBRL. The SEC has to offer up concrete reasons and real-world white paper examples of data mining given in-line XBRL. Just because it can be accomplished, the SEC needs to show us live examples of current in-use.

(5) Balancing Act.
Given that there are a significant variety of member tags that can be applied to any given element, and there are a significant number of elements that are marginally variable from each other, it is easy for any user to be skeptical of a claim that in-line viewing allows comparability between filings or between filers the user would be overwhelmed with sorting out HTML dissimilarities while trying to ensure comparison of appropriate periods, etc etc. all the while trying to focus on the element to see if it's similar at all to other filings he is reviewing.