Donald E. Vick Jr., CPA Controller LanVision Systems, Inc. 5481 Creek Road Cincinnati, OH 45242 Direct Dial (513) 794-7116 E-mail dvick@lanvision.com May 22, 2002 Jonathan G. Katz, Secretary Securities and Exchange Commission 450 Fifth Street, NW Washington DC 20549 Sent Via email to: rule-comments@sec.gov Re: File No. S7-08-02 Dear Mr. Katz, Thank you for the opportunity to comment on the SEC's proposed rule to shorten filing deadlines. While this proposed rule is certainly well intentioned, I am not convinced that investors will actually benefit. I am quite concerned that the effect of accelerating filing deadlines will greatly reduce the time necessary for proper analytical review and understanding of the underlying financial statements and will therefore increase the likelihood of errors or inadvertent omissions. As Controller of LanVision Systems, Inc. (publicly traded on the NASDAQ SmallCap market under the symbol LANV), I feel compelled to express my concerns against the proposed shortened filing deadline rules in an effort to represent the "little companies" in the market with limited resources. As a backdrop, LanVision is a very small company with roughly $11 million in annual sales, 65 employees, and an accounting department of 3 people. We pride ourselves in our ability to run a lean, yet very efficient, corporate infrastructure for the benefit of our shareholders. We are very concerned that accelerated filing deadlines, coupled with the ongoing need and desire for increased financial statement disclosure would be very burdensome and relatively costly for the many small companies in the market like LanVision. It seems to me that investors would be much better served to have additional filing requirements on the accuracy and completeness of the financial statements versus the speed of their preparation. While large Fortune 500 companies might increase their accounting staff or increase their use of external resources, the financial impact of these increased resources is not much more than rounding error. With a small company, the increase of even one or two people can make a noticeable difference in operating income. The limited resources of a small company would best be used to serve the business in an income producing role-not merely for back office accounting acceleration. I would think any shareholder would agree with this. In summary, the proposed rule to accelerate financial reporting could be very detrimental to the smaller public companies. Out of necessity small companies have already re-engineered their processes to achieve optimum efficiency. There is only so much slack in the system to play with. Let's use any increased efficiencies toward additional financial statement analysis and understanding or growth of the business; let's not focus on speed of financial statement preparation. Please consider the special needs of smaller companies when finalizing this financial statement acceleration rule. The suggestions to modify the requirements based upon company size make a lot of sense and would certainly be well received by those of us smaller companies. Thank you for your consideration. Sincerely, LanVision Systems, Inc. Donald E. Vick, Jr. Controller