Subject: File No. S7-08-10
From: Jay A McCarthy, Ph.D.
Affiliation: Assistant Professor of Computer Science, Brigham Young University

April 20, 2010

Securities and Exchange Commision:

I am a professor of computer science with expertise in the formal specification of programming languages.

I endorse the comments Sameer Sundresh has written on this proposal.

I would only add that it seems inappropriate to mandate any particular specification style. At the most, mandate that a specification exists and let those involved determine which specification style and language is most suited for the particular asset. No matter what the SEC mandates, it will be the wrong choice for some group.

Jay A. McCarthy
Ph.D, Computer Science, Brown University
Assistant Professor of Computer Science
Brigham Young University
Provo, Utah, USA