Subject: File No. 4-497
From: Marie Perry
Affiliation: Assistant Controller, Brinker International

April 14, 2005

1. Request guidance on de facto material weakness related to restatements correction vs. new interpretation

2. Forum to address current issues and concerns for both issuers and auditors

3. Ambiguity of certain guidance amongst issuers and auditors is leading to varying interpretations and the trend to do more work than is necessary. Request directional guidance on the overall approach. i.e. Spreadsheet controls, number and level of field work testing

4. Comprehensive cost/benefit report showing the expense incurred by issuers and the listed benefits of the current process