From: Gayle Essary
Sent: November 19, 2005
To: rule-comments@sec.gov
Subject: File No. 265-23


Dear Mr. Katz:

I would once more like to applaud the SEC's Advisory Committee on Smaller Public Companies and the SEC staff for the exemplary volunteer work that the committee is performing on behalf of investors and shareholders, and the public companies in which they are invested.

I have had the opportunity on several occasions to observe the work of the committee in public session, and their ethic and sincerity of approach, and its members can never be sufficiently rewarded for the good already accomplished.

At this time, I would like to once more follow up on my testimony and written submissions with the ATTACHED much more complete and comprehensive document submitted to Susan Matthews, Esq., SEC attorney supervising the Regulators associated with the Global Research Settlement, at her request.

It further delineates and expands upon the interactions between Investrend Research, Investrend Research Syndicate, FIRST Research Consortium, and lastly but not leastly, the Shareholders Research Alliance in their efforts, in aggregate, to continue, and to further codify, a lasting and working model to advocate and substantially increase research of uncovered and under covered public companies, impact their liquidities, and do so while advocating the adoption and practice of standards and ethics that are designed to eliminate conflict, bias and to spotlight unprofessional practitioning.

I would respectfully submit that the committee will perform a great service to shareholders and investors served by the SEC upon the endorsement of sponsored independent research that has as its basis published standards, ethics and procedures, and preferably, that the research process is monitored by the investors that the research serves.

Thank you again, and we look forward to the committee's final work product.

Gayle Essary
Managing Director, Investrend Research Syndicate / Investrend Research
Executive Director, FIRST Research Consortium
Interim Administrator, Shareholders Research Alliance
CEO, Investrend Communications, Inc.

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