From: Tony McDuffie [tmcduffie@harrahs.com] Sent: Tuesday, May 07, 2002 3:17 PM To: 'rule-comments@sec.gov' Subject: Comments on File No. S7-08-02 Harrah's Entertainment, Inc. One Harrah's Court Las Vegas, NV 89119 The Securities and Exchange Commission Office of Investor Education and Assistance c/o rule-comments@sec.gov 450 Fifth Street, NW Washington, D.C. 20549 RE: Proposal S7-08-02 Dear Sir/Madam: We appreciate this opportunity to comment on the Commission's proposed rule to accelerate the periodic report filing dates for quarterly reports and annual reports filed under the Securities Act of 1934. The proposal notes that there has not been a revision in reporting deadlines in over 30 years, despite advances in communications and information technology that are believed to have made it easier for companies to process and disseminate information swiftly. We believe, however, that equal consideration must be given to the increases in disclosure requirements that have occurred over the same period. To a great extent, the benefits of the technological advances have been offset by the additional effort necessary to comply with the expanded disclosure rules. We are concerned that the proposed accelerated filing deadlines may actually compromise the quality of financial reporting, since there may not be adequate time to thoroughly review the disclosures. In reaction to recent events, a number of additional disclosures have been proposed that would add to the disclosure preparation burden of most companies, further straining the balance between time available to prepare versus the quality of the financial reporting end-product. We would also expect that the acceleration of filing deadlines would almost certainly result in increased audit fees, particularly for calendar year-end companies, due to the greater supply-and-demand imbalance that will result between the work required and the audit staffing available during the already very busy year-end close period. We respectfully request that the Commission reconsider this proposal. If it is concluded that the current deadlines cannot be retained, we suggest that, alternatively, those deadlines are reduced by a shorter period, possibly to 75 days for the Form 10-K and 40 days for the Form 10-Q. Another alternative that might be considered to provide more timely information within the regulatory framework would be for the Commission to require a company to file its earnings release on the same day that information is issued to the financial press. Should you wish to discuss our comments further, please contact Tony McDuffie at tmcduffie@harrahs.com or (901) 762-8633. We appreciate your consideration of our comments. /s/ CHARLES L. ATWOOD Charles L. Atwood Senior Vice President, Chief Financial Officer & Treasurer /s/ ANTHONY D. McDUFFIE Anthony D. McDuffie Vice President, Controller and Chief Accounting Officer /s/ BRAD L. KERBY Brad L. Kerby Vice President, Corporate Counsel and Secretary