April 28, 2000

Securities and Exchange Commission
450 Fifth Street N.W.
Washington, D.C. 20549

Re:  Proposed Regulation FD (Securities Exchange Act Release No. 33-7787, File #S7-31-99)

Ladies and Gentlemen:

Internet Wire is the largest Internet-based distributor of company news, serving more than 2,300 corporate clients.  We applaud the SEC for its consideration of Regulation FD as a means of updating the antiquated and bottlenecked process of disclosing financial and material news from publicly traded companies.

Internet Wire advocates an Internet-centric disclosure model because the Internet is global in reach, broadly accessible, and widely used by news media professionals, industry analysts and individual investors.  The Internet is also uniquely capable of real-time dissemination on a worldwide basis without reliance on a proprietary platform owned or controlled by any company.

In addition, Internet Wire advocates that the Fair Disclosure of material news continue to include simultaneous delivery to the three leading financial newswires: Dow Jones, Reuters and Bloomberg News. Including these three services within the guidelines of Fair Disclosure protects the common practices and behaviors (when seeking and gathering company news) of the financial industry. When information from a publicly traded company is delivered simultaneously to these widely distributed media outlets, it is disseminated quickly and impartially by journalists to a worldwide audience, including offline outlets.

Furthermore, in pursuit of the best interests of the financial industry, Internet Wire requests that the US exchanges clarify precisely how member companies can meet their disclosure needs.  We propose that exchanges not advocate any specific paid-for distribution services by name, as they do now, but rather publish the requirements for meeting fair and timely disclosure.  By recommending specific paid-for services, the exchanges contribute to the current backlog of disclosure-related information coming through one or two limited pipelines, thereby creating the real possibility of delaying material news announcements.

Finally, by allowing an exchange to list a specific paid-for distribution service by name, it creates confusion as to the compliance of other services which fully meet SEC requirements, and also contributes to the appearance of a "governmental approval" of one or two of the largest distributors.  Internet Wire feels that such practices have the tendency to unfairly restrict competition and discourage innovation, as well as putting too much of the disclosure process in the hands of one or two corporations.


Michael J. Terpin
Chairman and CEO