Subject: File No. S7-08-19
From: Sam M Yaffa, Yaffa

August 6, 2019

I'm a young investor and I have noticed that an easy way for startup/early stage companies to go public is via a shell. However, shell companies have many stringent rules and requirements such as the evergreen rule which can hurt the investors who invested even after the now former shell has filed a form 10 or S-1 and waited a year. Can the commission provide a black and white path for shell companies to become fully-reporting companies, rule 144 eligible, and not be haunted by the evergreen rule?