Subject: File No. S7-06-13
From: Dan Ash

August 19, 2013

I appreciate your intentions to have new legisation to encourage investment in startups, however, your pentalties of 1yr for a misake is crazy.

Based on your current drafting, GOOGLE would never have been created

The founders of google met with an advisor one day to get some tips, and walked away with a 100K check - an unexpected first investment Under your rules, they would have been banned from any fundraising for 1 year because they didn't lodge a Form D 15 days earlier. They may never have launched. Then where would we be.

Please review this penalty as it is not practical.