Subject: File No. S7-23-08
From: Ralph D Allen
Affiliation: Managing Partner, BeaconAdvisors

August 6, 2008

Regarding the use of issuer's web sites for disclosure purposes, I would like to submit for consideration a possible shortcoming of this technique in terms of the broad distribution or availability of the information as I believe most such information is currently obtained and used.

Apparently under the proposal, issuers would not be required to accompany new disclosure material posted on their web site with press releases. My concern centers on the fact that most investors...individual and professional, obtain most of their investment information via third party organizations such as Bloomberg, Brokerages, Mutual Funds, YahooFinance and the like. Normally such sites highlight "news" flagged when releases are made or when news coverage is noted.

Some provision should be made for information disclosed via an issuer's site to also be noted by such third party providers. Otherwise investors will be required to regulary visit the sites of every company they own/follow for the purpose of reviewing any new disclosure.