Subject: File No. S7-05-00; Rulemaking for EDGAR System, #3

Date:    03/21/2000 5:24 PM
     
     
     
     
March 20, 2000
     
Jonathan G. Katz, Secretary
Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C.  20549
     
Re:  File No. S7-05-00; Rulemaking for EDGAR System
     
As part of the rulemaking for the EDGAR System, Global Securities 
Information urges the Commission to set a careful and explicit definition 
for what constitutes the official content of an EDGAR filing.  These 
definitions are very important to anyone who will be doing anything more 
sophisticated with these documents than viewing them on the Internet, such 
as extracting them or compiling them, or to anyone who receives EDGAR 
information through one of the many services that are not Web-based.  
     
Prior to EDGAR version 6.0, the SEC accepted only text documents formatted 
with SGML.  For those documents, the definition of official content was 
simple -- all text between the "TEXT" SGML tag and the "/TEXT" SGML tag was 
official content.  We encourage the commission to continue this definition 
for plain text documents.
     
With EDGAR 6.0, the Commission began accepting documents in HTML format. 
These documents present a problem in that they contain a great deal of 
formatting information that is not visible to the end-user.  Currently, the 
official status of this invisible formatting information is unclear. We 
propose that the Commission rule that the official content of an HTML 
document be just that portion of the document which is visible when the 
document is viewed using either of the two most popular Internet browsers, 
Microsoft's Internet Explorer or Netscape's Navigator.
     
With EDGAR 7.0, the Commission has proposed allowing graphics and links in 
HTML documents.  We propose that the Commission rule that these included 
graphics and links be considered unofficial content, as PDF content 
currently is.  A graphic or a link has a meaning that can be ambiguous and 
transitory, and is not appropriate for a uniform disclosure document.  In 
addition, this content is meaningless when a document is extracted or viewed 
using something other than a browser.  Note also that the SEC is not 
currently planning to verify the validity of either the graphics or the 
links before they are disseminated to feed subscribers.  
     
We feel that it would be appropriate to extend the treatment given to 
unofficial PDF content under Rule 104 to other unofficial content, so that 
all unofficial content in prospectuses retains prospectus liability under 
Section 12 of the Securities Act.
     
Whether or not the Commission agrees with our positions on these issues, we 
urge the Commission to address them before the final rulemaking.  In the 
absence of guidance from the Commission, feed disseminators will have to make 
their own judgments when converting documents from HTML for the benefit of 
customers who chose not to use a browser-based interface.
     
Sincerely, 
Nicholas B. Keenan
Chief Technology Officer
Global Securities Information, Inc.