Subject: File No. S7-06-03
From: Ronald W. Burgess

September 11, 2006

Dear Sir/Madam:
As the CFO of a non-accelerated filer I certainly welcome the delay provided by the current ruling. However, it is important to note that this does not address the substance of the issue related to putting the full weight of 404 requirements on smaller public companies. I strongly urge the committee to take the opportunity this delay presents to rethink the need to burden smaller entities with the complexity and administrative cost of compliance. Having limited resources and less complex business structures, this requirement presents an unnecessary and disproportionate cost for smaller filers.
Very truly yours,
Ronald W. Burgess
Key Technology