December 18, 2002
Mr. Jonathan G. Katz
Re: Sarbanes-Oxley Act §307 - Implementation of Standards of Professional Conduct for Attorneys - Part 205 (File No. 33-8150.wp)
Dear Mr. Katz:
We are writing to you with respect to the captioned rules currently proposed by the Securities and Exchange Commission (the "Proposed Rules").
As one of the largest Japanese law firms with approximately 110 attorneys, we share the concerns expressed by the Japan Federation of Bar Associations in its December 14, 2002 letter to you regarding the Proposed Rules. We therefore wish to express our support for and join in the request of the Japan Federation of Bar Associations that foreign attorneys who do not practice laws in the United States or practice any state or federal law of the United States be exempted form the attorney-reporting duties under the Proposed Rules.
Thank you for your consideration of this matter of importance.