From: Lee Level (Computer Sciences Corporation)
Sent: Tuesday, March 16, 2004 5:44 PM
Subject: (PCAOB-2003-11) Request for Comment Period on PCAOB "Final
Rule" on Audits of Internal Controls Over Financial Reporting

Jonathan G. Katz, Secretary
U.S. Securities and Exchange Commission
450 Fifth Street N.W.
Washington, D.C. 20549-0609         (filed electronically via
                                     rule-comments@sec.gov)

subject:  Request for Comment Period on PCAOB "Final Rule" on Audits of
Internal Controls Over Financial Reporting

Dear Mr. Katz:

We have read unofficial accounts stating the Commission will formally
provide a comment period before approving the recent PCAOB "final rule" on
audits of internal controls over financial reporting.  As submitted to the
SEC, the March 9 PCAOB rule does not appear to address many important areas
raised in the nearly 200 related comment letters filed with the PCAOB
during Fall 2003.  Realizing companies have to comply within eight months,
we strongly urge the commission to hold the comment period for public
companies, accounting firms and others to be heard on how the numerous
prior comment letters have, or have not, been addressed.  From my comment
letter of November 21, 2003 attached, the following are examples of areas
we think warrant more consideration before approval of the final rule:

   1. Balancing the cost of these measures with resulting benefits

   2. Revising the overly broad and all-encompassing nature of the proposed
   definition of a significant deficiency

   3. Reducing the overly prescriptive and exhaustive scope of certain
   required audit procedures

   4. Balancing the prohibitively high cost of these audit procedures with
   commensurate benefits

   5. Reconsidering the enumerated presumptions of significant deficiency
   and strong indications of material weakness

   6. Considering the "expectations gap" where, in addition to the overall
   cost benefit disparity, we are even more concerned with the widely held
   misperception that audits of internal control will eliminate business
   and financial reporting failures.  We fear this expectations gap may
   serve to further undermine our markets when we experience the next
   serious business and financial reporting failure.  At least in part,
   this expectations gap has resulted from unrealistic expectations created
   by some of the recent rule-making initiatives, e.g., expectations
   regarding "certifications" and registrants' ability "ensure" financial
   reporting.

We appreciate the Commission's consideration of offering a brief comment
period as part of due process in issuing such a far-reaching requirement.
If you have any questions or would like to further discuss our comments,
please feel free to contact Dennis Dooley at (248) 372-3306 or me at (310)
615-1728.


Sincerely,


Leon J. Level
Chief Financial Officer

(See attached file: PCAOB Reporting on Internal Control Comment letter.doc)

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| website, http://www.pcaobus.org/pcaob_rulemaking.asp, under   |
| Docket #08.                                                   |
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