Subject: File No. S7-06-13
From: James A Knight
Affiliation: CEO, Pelletco, LLC

July 20, 2013

I am deeply concerned that the proposals you have put forward are far too onerous for a small start up company.

In reading through your proposals they seem geared to companies raising multiple millins of dollars. For a small company to comply with the requirements you propose will force up legal and other professional advisory fees which already compose a very significant expense for a small company. In addition to the cost on profesisonal fees i fear your proposals will impose large time requirements on a small comany's executives. Also, the small company does not realistically have the resources to complete some of the investigative tasks you contemplate.

While I appreciate your desire for more data and investor protection perhaps you will consider a streamlined and less onerous process for issuers of say under $5M?

Thank you.