From: Arnold D. Sobol [sobola@acm.org]
Sent: Wednesday, September 25, 2002 10:14 PM
To: SEC
Subject: Comments on File No. S7-31-02

My company markets a software product that produces both printed Forms 3, 4
and 5 and files to transmit to EDGAR. My comments are addressing the adding
of column 2A to Table I and column 3A to Table II for optional deemed
execution dates.

My concerns arise because real estate  in these tables lines is at a premium
in both the forms and EDGAR with its 132 characters per table line
restrictions and these new columns by themselves will not contain
unambiguous information. A poll of our users indicates that the column will
be infrequently used and when it is used it will be necessary to footnote
it.

I am recommending that footnoting the associated transaction date columns 2
and 3, when necessary, with the deemed execution date information would
satisfy the regulations. If this is an acceptable option then columns 2A and
3A would not be required on the forms.

Arnold D. Sobol
Partner
R&W Software
1115 19th Street
Santa Monica CA  90403
www.randwsoftware.com
sobola@acm.org