From: Richard B. Miller
Sent: February 16, 2007
Subject: File No. S7-25-06

This email is in reference to a proposed rule change for File No. S7-25-06 relating to an Accredited Investor. Having invested in a number of private placements, I feel the proposed qualification of $2,500,000, excluding a residence, is excessive. I qualify under that rule, but a number of friends and business associates who do invest in private investments do not. However, they are well qualified to make intelligent choices on investments. From my experience, selecting an arbitrary figure of $2,500,000 is not a valid measure of one's degree of acumen on investing. If you require a level, set it at $1,500,000, 50% higher than the current level.

Richard B. Miller