Subject: File No. JOBS Act Title III
From: Robert McManus

January 28, 2014

Dear SEC personnel,

I would encourage you to look to the book "Slicing Pie" by Mike Moyer as a guide for the JOBS ACT.

As a former equity financial analyst, and decade long interpreter of SEC documents filed by public companies, I am intimately knowledgeable of the uses, misuses and pitfalls of SEC documents.

Currently, I have founded a start-up beverage alcohol company ( and am using the principles outlined in the book Slicing Pie. This book is a very straightforward set of methodologies and principles with which to present the financial picture of a new business to participants. I believe that an earnest, transparent and principled use of this book can be easy for an entrepreneur and her/his team and useful to employees, equity investors, debt investors and others.

I have strong opinions on the ability of public companies to provide gibberish in SEC 10K's, Q's, 8Ks, etc that conform to your reporting requirements, yet yield no information to investors. If you were to incorporate the principles of "Slicing Pie" you would go a long way towards not repeating the mistakes that allow already public companies to provide meaningless information.

Feel free to contact me with any questions, comments or elaboration.


Robert McManus
The 11 Wells Spirits Company
St. Paul, MN 55106