From: Julia.Harper@radisys.com Sent: Monday, May 13, 2002 3:12 PM To: rule-comments@sec.gov Subject: File No. S7-08-02 - Accelerated Reporting Deadlines I am writing to provide comments on the proposal to accelerate reporting deadlines for 10Q reports from 45 days to 30 days and for 10K reports from 90 days to 60 days. As the CFO for a mid-sized high tech company, I have serious concerns about this proposal. While I understand that the intent of this proposal is to provide more visibility sooner to the investor, I do not believe that it addresses the true issues that exist in today's financial marketplace. In the current environment, most investment decisions are made based on company earnings releases which include a tiny fraction of the information required in 10Q and 10K reports, and are generally available within two to three weeks of period-end. Analysts and institutional investors routinely participate in conference calls which are scheduled concurrently with the earnings releases. This provides a forum where additional information and disclosure is provided - supposedly on a level playing field as the conference call is referenced in the earnings release and is open to any and all participants. Participation in these calls by the "average investor", however, is essentially nonexistent, therefore the average investor is disadvantaged. Moving the reporting date for 10Q's and 10K's which include full disclosures does not eliminate this disadvantage. The disadvantage is really only eliminated by tying together the release of earnings information and the reporting date. Accelerating the reporting date creates an unreasonable burden and level of risk on public companies - especially for growing, young companies who already have high administrative costs relative to their revenues and earnings. We are operating today in a world of ever-increasing requirements for disclosures, increasingly complicated and rapidly changing accounting rules and higher levels of risk with regard to reporting and disclosures. Asking for more and more information while decreasing the time allowed to accumulate, analyze, scrub and publish that information is neither reasonable nor prudent. While I applaud the effort to level the playing field for all investors, I respectfully submit that this proposal creates additional hardship on public companies and does not deliver the desired affect. Julia A. Harper Chief Financial Officer Radisys Corporation