Subject: File No. S7-06-13
From: Elliott Counts

August 18, 2013

As many of us are very well aware, startups are creating products and solutions to vast problems. At the early (fragile) stages, forcing startups to meet additional SEC requirements would pose as a hindrance and a distraction to the company. While, yes, the startup would/could suffer potentially severe consequences from not meeting the SEC's stipulations, IT IS the general public that would suffer most.

New ideas, new solutions, and new companies are the driving force for the new economy and inherent competition will prove whether the company can produce viable products and be able compete within their given marketplace. From an altruistic perspective, removing one line of 'red tape', but placing 3 more in the way does not show progress, but is a sign of regress.

This is not just a comment, but a plea that the SEC refrain from being held accountable in the event that it plays a role, no matter how large or small, in the plausible failure, or best case scenario, 'postponed' success of the company.