Subject: File No. S7-25-06
From: Kevin J. Koons

January 28, 2007

There needs to be a balance between levels of wealth, experience and sophistication, when qualifying potential investors for private placement investments.

Experience and sophistication should require lower levels of protection such as a total net worth of at least $1,500,000.

Lack of experience and sophistication should require higher levels of protection such as a total net worth of at least $3,000.000.