Subject: File No. S7-06-13
From: Joseph Ng

September 25, 2013

It has been difficult to comply with SEC filings for a $75M company with a dedicated SEC reporting manager plus accounting staff let alone a start up. During start up phase, all attention must be directed to product and customers and not SEC reporting. The best approach forward is to let funders, who have credible filing experience, do the filings on behalf on start ups as part of the fundraising and investor communication.