From: Geoffrey Grier
Sent: December 7, 2005
Subject: File No. 265-23

To All Those Concerned:

I have worked as a performance graph provider for thousands of publicly traded companies. This is a mandated SEC item required for inclusion in the executive compensation portion of the proxy (DEF 14A) or in some cases the 10K.

I believe in lieu of some the weighty SOX accounting procedures small business companies have to file, they would be better serving their shareholders, the SEC and themselves if the performance graph was required on an annual basis to support and help define a clear line of performance. Especially if the small business thresholds are increased from $25 million in market cap or revenue to $100 million or beyond as some proponents are proposing. This ought to promote more transparency in an area where a tighter regulation system is needed, especially when facing the possibility of more shares and cash being freed up for executive compensation. These are not clearly tracked items for the general shareholder unless tied to a performance chart.

I am not in favor of necessarily increasing the volume of required filing material but refining the techniques through user friendly items. This item is such a visually clear picture of the company and how it is doing, that shareholders, compliance officers and financial analysts generally buried under reams of text could make a fair assessment of where the company stands. Not to mention the backbone of publicly traded companies, the shareholder.

Geoffrey Grier
Sr. Vice President Marketing & Sales
Proxy Service Division
Research Data Group, Inc.
3450 Third St. #3F
San Francisco, CA 94124