Subject: File No. S7-26-18
From: L. Overholt

March 20, 2019

I don't see any need to change the quarterly reporting period. I listened to the former CEO of Medtronic about this. As long as the proper range is given for guidance, his points would not matter. If guidance is missed because of something like more RD spending, there was probably something wrong with the guidance.

I am definitely against lengthening the quarterly reporting period. I can see that leading to more chances of misinformation in the market. I am not in favor of any flexibility as to the frequency of the periodic reporting. All entities play by the same set of rules.

Leave the quarterly reporting period as it is.