Subject: File No. S7-06-13
From: Kerem Durdag

September 5, 2013

I can provide a succinct summation: Start-ups have significant and overwhelming amounts of activities to manage and worry about and to accommodate the proposed SEC rules is back-breaking, time-wasting and non-productive... at least exempt those raising under $1-2 million in specific venture rounds.

I know the Feds want to "protect" the uneducated entrepreneurs from "evilish and unscrupulous" folks with money... and I applaud that (completely support it)... but at the same time they need to make the activity not something that is suffocating. And the current proposed rules are suffocating.

I have been blessed in being a successful high-tech manufacturing start-up entrepreneur (also am an investor in start-ups) who has had his share of stellar failures. I have also been on executive management teams of large public companies. And I continue to be in trenches of what constitutes the backbone of our economy: young companies that innovate, push beyond the boundaries, partner up with large companies, get needed and urgent products to market with scalability and cost-effective pricing and are forward leaning enough to leverage, multiply and create jobs. So take it from a veteran: don't suffocate us under paperwork and let's find a balance between protecting our interests, safeguarding from predatory behavior and ensuring a level playing field for all.