Subject: File No. S7-05-00 (EDGAR format changes)
 
Date:    04/18/2000 6:59 PM
     
     
    Hidden deep in the proposed changes to EDGAR appearing at 
     
http://www.sec.gov/rules/proposed/34-42462.htm
     
    is the complete elimination of the Financial Data Schedules.
This seems a bad mistake.  Those schedules allow for direct 
extraction of the fundamentals of a company from the official 
filings. 
     
    If the technical objection to continuing the Financial Data
Schedules is that SGML seems obsolete and incompatible with HTML, 
consideration should be given to re-expressing the Financial
Data Schedules in XML, using the same tags used in SGML. 
This would provide the Government with a low-cost 
transition to a new technology, and the public with an 
official, machine-processable source of this data.  
     
    We were planning to use this data to attempt to predict
when money-losing startups will run out of cash, as a form 
of investment advice.  We will no longer be able to do so.
     
    We recognize that this comment is submitted late, but we
do not yet see any comments on this rulemaking on your web
page at http://www.sec.gov/edaux/moderniz/emodrule.htm although 
the notice of proposed rulemaking indicates that such comments 
will appear online.  So we ask that this comment be considered 
timely.  
     
    Thank you for your attention to this matter.
     
                                                John Nagle
                                                Downside.com
                                                999 Woodland Avenue
                                                Menlo Park, CA 94025