Subject: File No. S7-38-04
From: Andrew P Naples

January 8, 2005

After experiencing massive losses, the obvious goal, as perceived by the small investor, of the IPO is to allow the original investors to free up some of their initial investment in the organization at the expense of the small investor. This freeing up of capital is usually at the expense of a small investor that is looking for a homerun of sorts in his investment portfolio. The marketing hype of the company during the roadshow somehow seems to wrongly influence the press which in turn influences the small investor.

I would recommend a fixed issue price of at a P/E cap of 15 on the current year earnings only if the company has made money for the past five years. The SEC will not allow an IPO to take place if the firm has only four years of positive and increasing earnings.