Subject: File No. S7-11-13
From: George W Beard

March 21, 2014

Since '33 and going forward, Tier 1 Reg. A offers speed and cost advantages even though general Test The Waters (TTW) radio ads to everyday commuters can be heard ONLY in "free states".

Any and all adult citizens of cities and towns in those jurisdictions, stretching from Washington DC to Washington State, who "coordinate with the SEC" will be free to boost their economies, i.e. to establish local ventures in competition with Silicon Valley. By quickly registering Tier 1 shares/Units issued in these 'free' states on the TSX-V and then doing TTW ads again the next year etc., even Post Docs can afford to get ideas off shelves and eventually even qualify for an EB-5 visa.

Following the new company's 3rd (5th?) anniversary, the audited, TSX-V-listed venture's Unit-holders could elect either a Tier 2 offering or, by exercising their own direct IPO (EOIPO) rights, place the company on the NYSE themselves.

More often than not, this 'Beacon Model' of fast and highly sustainable publicly supported growth will appeal to cost-constrained founders who prefer to build and operate a great company without losing control of their intellectual property, while retaining the freedom to pivot whenever that makes sense and enjoying this unique opportunity to earn their EB-5s.