Subject: File No. S7-04-11
From: Robert M Davis
Affiliation: General Manager, Omniteam, Inc.

February 1, 2011

Approximately 7-8 years ago, I began investing in real estate related projects thru a single company in San Diego, CA. At that time, they asked me to complete an accredited investor document, with no explanation attached. I must admit that I had no idea of how the document was to be used. I have participated in five projects with this single entity and completed the accredited investor document each time, with an approximate net worth of $1.2mm-$1.3mm, which included roughly $0.5mm of equity in my home. Two of the projects have been completed and my investment returned. However, at this point, I have $337,436 invested in the remaining three projects with very little hope of seeing any return of my capital within 5 years, and, certainly, no hope of seeing 100% of my funds.

I believe that the SEC should and must hold companies to a higher standard when they solicit investment funds for multiple projects from a single investor. I funded these investments via a HELOC, and, as you must realize, the value of my home has decreased by 25%. I'm 63 and extremely close to retirement and now realize how much I would have appreciated stricter SEC regulations that might have prevented me from investing in multiple projects with the same entity.