Subject: File No. S7-06-13
From: Lenny Turetsky
Affiliation: Principal, First Gear Consulting

August 19, 2013

To whom it may concern,

While I appreciate and commend the SEC's efforts to open up financing for the kind of ventures I've made my life's work, I must protest the rules that I've seen so far as counter-productive. I could not advise a client or co-founder to attempt to raise funds under these rules as an error would automatically disqualify the company from fundraising for a year: certain death for a startup. In my entire career I've never seen a startup avoid making mistakes in fact, making mistakes and correcting them quickly is the hallmark of successful entrepreneurship. But a 12-month cycle for correcting errors is the antithesis of such learning.

Please reconsider these rules and help us learn to comply with them more smoothly.

Thank you,
Lenny Turetsky