Subject: File No. 265-23
From: Richard A Karp
Affiliation: Chairman and CEO, Catapult Communications Corp.

March 21, 2006

I am the CEO and Chairman of Catapult Communications, a Nasdaq National Market Company that is in our second year of having to comply with SOX404 attestation requirements. We would fall under the proposed partial exemption. Our SOX costs in our first year totaled in excess of $2 million, in excess of 3% of gross revenues. Absurd though that level of expense may be for Catapult, in terms of the effect on our time and competitiveness, however, the actual cost was difficult to quantify but clearly much higher.

High costs continue in our second year and will continue forever unless changes are made.

None of our principal competitors are subject to SOX404 as most are foreign companies that are either private or not listed on a U.S. exchange. As a company that exports U.S. manufactured product we are at a serious cost disadvantage against foreign competition solely due to SOX404. I urge the SEC to adopt the proposed changes without further modification as soon as possible. Every day delayed is a day too long.