From: Mike Boyle [mike.boyle@techbooks.com]
Sent: Thursday, April 25, 2002 12:58 PM
To: rule-comments@sec.gov
Subject: TechBooks Financial response to proposed rule, File No.
S7-08-02

Dear Mr. Katz:
	
Since our primary focus is as a supplier in the EDGAR chain, we will 
confine our comments to the technologies and processes involved with 
the proposal. 

The proposal repeatedly and convincingly makes the case for how much of 
a dramatic and positive impact the Internet has had on the 
dissemination of information, how it has “democratized” the global 
investing community and generally allowed for an unrestricted free flow 
of information.  We could only concur with all of these points.

However, a significant omission in the proposal is a lack of a 
definitive statement by the commission on the near-term and long-term 
status of EDGAR II. Will it be mandated? When will it be mandated? Will 
it be bypassed in favor of something else such as XML?  It is not an 
unlikely scenario that a company would be in favor of the accelerated 
filing schedule based on its current document preparation 
infrastructure, yet could find themselves completely unprepared if an 
EDGAR II filing mandate comes down after acceptance of this proposal.

Many Corporate and Investment Management companies, as well as EDGAR 
preparers and filing agents, are currently caught in an electronic no-
mans-land between ASCII and HTML filings. Unwilling to move forward due 
to the unknown status of EDGAR II, yet unwilling or unable to devote 
more resources to what soon might be an obsolete system.

It is our opinion that this issue goes hand-in-hand with that of the 
accelerated filing proposal and website access. Therefore, we would 
urge the commission to postpone this decision until it has clarified 
the future of electronic filing. 

Further, we would also ask that you provide a timeline for your stated 
plans to eliminate the 24-hour delay for filings posted to your 
website, thus providing real-time posting of disseminated filings.

Thank you for the opportunity to comment on this proposal.

Sincerely,

Michael J. Boyle


Michael J. Boyle
Director of Publishing Technologies
TechBooks Financial
781-465-2000
mike.boyle@techbooks.com
www.techbooks.com