U.S. SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C.

Litigation Release No. 19487 / December 7, 2005

Accounting and Auditing Enforcement Release No. 2353 / December 7, 2005

SEC v. Corder, et al., Civil Action No. 1:03-CV-1436, JDT-TAB (S.D. Ind.)

SEC Settles with Officers in Financial Fraud Case

The Securities and Exchange Commission ("Commission") announced that an order of Final Judgment was entered against Defendant Randal J. Sage ("Sage"), the former Chief Operations Officer of Analytical Surveys, Inc. ("ASI"), in SEC v. Corder, et al., Civil Action No. 1:03-CV-1436 (S.D. Ind.). Sage, a resident of Carmel, Indiana, consented to the entry of the Final Judgment without admitting or denying the allegations made against him in the complaint filed by the Commission. The complaint, filed in October 2003, alleged that from at least October 1998 through at least December 1999, Defendants Sage, Sidney V. Corder ("Corder"), the former Chairman, President and Chief Executive Officer of ASI, and Brian J. Yates ("Yates"), the former Controller of ASI, engaged in a scheme to defraud investors by fraudulently inflating ASI's revenue and earnings in press releases and periodic reports filed with the Commission. The complaint alleges that Defendants caused ASI to recognize excessive revenue on long-term contracts through the use of several improper accounting methods that did not comply with Generally Accepted Accounting Principles ("GAAP").

On December 2, 2005, the Honorable John D. Tinder entered a final judgment: (1) permanently enjoining Sage from violating Sections 10(b) and 13(b)(5) of the Securities Exchange Act of 1934 ("Exchange Act") and Rules 10b-5, 13b2-1, and 13b2-2 thereunder and from aiding and abetting violations of Section 13(a) of the Exchange Act and Rules 12b-20, 13a-1, and 13a-13 thereunder; (2) prohibiting him from acting as an officer or director of any issuer that has a class of securities registered pursuant to Section 12 of the Exchange Act or that is required to file reports pursuant to Section 15(d) of the Exchange Act; and (3) ordering disgorgement of $376,277 plus prejudgment interest of $135,495, for a total of $511,772, but waiving payment of all but $185,000 of the disgorgement and prejudgment interest, which will be paid pursuant to a three-year payment plan, and not imposing a civil monetary penalty, based on Sage's sworn representations in his statement of financial condition.

Previously, on August 9, 2005 and January 3, 2005, Judge Tinder entered final judgments against Corder, a resident of Zionsville, Indiana, and Yates, a resident of Colorado Springs, Colorado, to which they consented without admitting or denying the allegations in the Commission's complaint. These final judgments permanently enjoin Corder and Yates from violating Sections 10(b) and 13(b)(5) of the Exchange Act and Rules 10b-5, 13b2-1, and 13b2-2 thereunder and, as control persons, Section 13(a) of the Exchange Act and Rules 12b-20, 13a-1, and 13a-13 thereunder. The judgment against Corder also prohibits him from acting as an officer or director of any issuer that has a class of securities registered pursuant to Section 12 of the Exchange Act or that is required to file reports pursuant to Section 15(d) of the Exchange Act and orders disgorgement of $554,108, plus prejudgment interest of $206,352, for a total of $760,460, but waives payment of all but $260,000 of the disgorgement and prejudgment interest, which will be paid pursuant to a two-year payment plan, and does not impose a civil monetary penalty, based on Corder's sworn representations in his statement of financial condition. The final judgment entered against Yates also prohibits him from acting as an officer or director of any issuer that has a class of securities registered pursuant to Section 12 of the Exchange Act or that is required to file reports pursuant to Section 15(d) of the Exchange Act for a period of five years and orders disgorgement of $202,704 plus prejudgment interest of $69,871, for a total of $272,575, but waives payment of all but $40,000 of the disgorgement and prejudgment interest, which will be paid pursuant to a three-year payment plan, and does not impose a civil monetary penalty, based on Yates' sworn representations in his statement of financial condition.