Subject: S7-05-20
From: Joe Daniluk

Mar. 29, 2020

To: Securities Exchange Commission

Subj: Rule Change S7-05-20
Regulation Crowdfunding is one of the most important SEC Regulations ever enacted. It is a great rule, providing a needed path for innovation and small business to come to life, but the $1.07m limit is too low for the following reasons, most importantly:
A Reg A+ or other types of offerings are too costly for a startup to utilize when raising capital, especially when there is a manufacturing aspect involved, such as ours has. Manufacturing costs can quickly consume $1m leaving little for capitalizing the remainder of the business operations. A $1.07m CF-Raise incurs a cost ratio of 30 to 40% over time of the actual funds raised, in promotional and related costs, leaving the net raised for capital at $600 to $700k of the $1.07m raised. It will require multiple years to reach a net capital of $1.07m raised and deployed in the business. Raising the limit threshold to $5m will significantly reduce this ratio, as time required is significantly reduced, and the benefits directly impact the issuer and its ability to enter the economy more quickly. There are numerous other reasons which could be included, but with CV-19 impacting the world economy, we would only point out that any and all efforts by our regulatory bodies that can help re-ignite the economy should be undertaken without delay, and opening the Capital Flood Gates a bit wider can only HELP!
The proposed release 33-10763 in its entirety, has no negative impact on any citizen / investor, but its Impact on the economy is all positive and everyone will benefit from the outcome. 
Please implement the changes sooner than later and increase the CF limit to $5m.
Joe Daniluk, CEO