April 3, 2006
ICOS designs and manufactures inspection equipment for the semiconductor packaging industry. Our 2005 revenues were approximately Euro 80.6 million ($100.3 million) and our market capitalization was approximately Euro 312.9 million ($363.0 million). Accordingly, we would be considered a smallcap company under the Advisory Committee's proposed recommendations and would qualify for the exemptive relief from external auditor involvement in the Section 404 process.
We support recommendation III.P.2 contained in the exposure draft of the Final Report of the SEC's Advisory Committee on Smaller Public Companies.
Exemption from the auditor attestation prong of Section 404 would help ensure that smaller public companies implement effective internal controls over financial reporting without bearing the extra costs associated with an auditor's attestation of management's assessment of those controls.