Subject: File No. 4-500
From: J. Richard Iler
Affiliation: SiriCOMM, Inc
May 2, 2005
As Chief Financial Officer of a micro-cap company, the cost of attracting capital is becoming ever more formidable by not only complying with Sarbanes Oxley, but also by the practices of broker-dealers and hedge funds who seek to manipulate the value at which they will invest in a PIPE. The common practice has been to “short” such shares on a thinly traded issue. The “financing” rather than being an investment is more a financial transaction to the “investing” party.
As micro-cap companies are being held to a disclosure standards of much larger companies, it should similarly hold that those investing be held to a similar standard. In order for all investors to be properly appraised of the inherent risk in investing in a company whose stock may be improperly manipulated, we would hope that this information as to short interest may be readily available for a prudent investor to assess the risk.
We respectfully ask that you please give the proposed rule your careful consideration.
J. Richard Iler