Registrant's principal executive officer and
principal financial officer, following an
evaluation within 90 days prior to the filing
date of this Report of the disclosure controls
and procedures as defined in rule 30a-2(c) under
the Act applicable to the Registrant's service
providers in connection with the services such
providers have agreed to provide Registrant,
conclude as follows:

1.the disclosure controls and procedures reflect
a cumulative process involving the Registrant's
service providers;

2. the cumulative process seeks to ensure that
the information required to be disclosed by the
Registrant in the reports that it files or submits
under the Securities Exchange Act of 1934 is
recorded, processed, summarized and reported within
the time period specified in the Commission's rules
and forms and that the information required to be
disclosed by the Registrant in  these reports is
accumulated and communicated to the Registrant's
management including its principal executive and
financial officer, as appropriate to allow timely
decisions regarding required disclosure; and that

3. this process is effective with regards to  its
purpose.