Subject: S7-05-00

Date:    03/13/2000 10:09 PM
     
     
March 13, 2000
     
Jonathan G. Katz, Secretary
Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C.  20549
     
Re:  File No. S7-05-00; Rulemaking for EDGAR System
     
This letter is being written in response to the Commission's request for 
comments concerning current and future EDGAR rulemaking projects.
     
I would urge the Commission to cease its efforts to ultimately require that all 
filings be made in HyperText Markup Language (HTML).  There are many 
disadvantages to the use of HTML and they were summarized (at page 22) in a 
recently published study, "Electronic Distribution of Business Reporting 
Information," sponsored by the Financial Accounting Standards Board:
    a.. Browser may split tables and pages, 
    b.. Document printed from browser will probably not look like original
document, 
    c.. Can require significant work to convert original document to HTML
document in terms of layout and design.
I view the EDGAR database as a repository for serious researchers.  HTML 
diminishes the utility of the EDGAR database for such individuals.  If the focus
of the user is on one filing of one registrant, HTML is the preferred format. 
This is seldom the case.  If this is the user's need, he/she can access the 
filing (complete with graphs and hypertext links) at the registrant's WWW site.
     
For example, suppose a user wishes to compare the environmental disclosures of 
the registrants in a certain industry.  With the ASCII format they are easily 
located through word searches and specific paragraphs can be copied and 
printed-out in a format which is easy to read, compare and analyze.  Such a task
is much more difficult if the original is in the stylized HTML format.  Plot 
points are more valuable than a graph and a visual guess as to the amounts. 
Requiring registrants to use HTML and hyperlinks is a classic example of form 
over substance.
     
A cost-benefit analysis has been performed solely from the viewpoint of the 
registrant or filer.  This analysis should be expanded to include the viewpoint 
and needs of user groups, including those who access the EDGAR database for 
research purposes.
     
In my opinion, the Financial Data Schedule should be discontinued unless it is 
useful to the Commission staff.  Under the present guidelines, certain financial
data is required to be disclosed in a Financial Data Schedule but is not 
required to be prepared or filed under generally accepted accounting principles 
or Regulation S-X.
     
The Commission has undertaken an important initiative concerning selective 
disclosure.  Instead of devoting resources to establishing and maintaining an 
HTML database, the Commission should (i) refine its systems to provide for the 
immediate availability to investors of any and all current event filings on Form
8-K, and (ii) improve the search capabilities of the EDGAR database.  This would
truly further the Commission's mission of being the investor's advocate.  Making
documents more attractive through the adoption of HTML does not.
     
     
Very truly yours,
     
Louis K. Miller
Berwyn, PA