Subject: File No. S7-24-06
From: Richard A Karp
Affiliation: Chairman and CEO, Catapult Communications Corp.

January 10, 2007

Generally, the longer the document, the lesser the content. This is a very long document.

Despite all the meetings, all the roundtables, all the debate, the SEC still has no idea how much small public companies have been punished by the current rules.

Long ago, a single piece of misguided legislation, the Smoot-Hawley tariff act, hastened America's entry into the Great Depression.

Historians will look back on the SEC's misguided efforts on SOX 404 as the modern day equivalent of Smoot-Hawley. Someday, a future Commission will fix this problem, but the current SEC has made it clear by this proposal that this fix will come too late for us and all other current small public companies.

Don't you people EVER really listen to anyone outside the Beltway?