Date:    04/04/2000 9:48 AM
     
     
To:     rule-comments@sec.gov
From:     Phil Acquaviva
Subject:  File No. S7-05-00
     
I am an end-user of financial analysis software (Spredgar) that depends 
on Edgar's filings remianing unchanged.  Eliminating the financials 
would enable many companies to escape proper due diligence for 
investors.  Eliminating this data would probably weaken the value and 
intent of all Edgar filings.
     
"We strongly object to the proposed elimination of the Financial Data 
Schedule (FDS). The FDS
contains the only consistent and comparable data found in the 10-K and 
10-Q filings.
     
Spredgar Software's SPREDGAR add-in for Microsoft Excel uses the FDS 
section to generate
over 30 standard financial ratios, as well as quarter-by-quarter free 
cash flow. Literally thousands of
financial analysts, students, professors, CPAs, corporations, and 
individual investors have used
SPREDGAR to assist them in their equity analysis. Many of these users 
have taken advantage of
our free trial offer and were able to perform their analysis at no cost 
to them.
     
SPREDGAR's corporate users include Hewlett-Packard, KPMG International, 
Lucent
Technologies, Prudential Securities, and Esteé Lauder. Our academic and 
nonprofit users include
the University of California at Berkeley, the University of 
Massachusetts, Texas A&M University,
and the Illinois Society of Certified Public Accountants."
     
Best regards,
Phil Acquaviva