File No. S7-08-02...A Proposal with dangerous consequences...From: Jerry Graves [Jerry.Graves@efi.com]
Sent: Monday, April 29, 2002 7:55 PM
To: 'rule-comments@sec.gov'
Subject: File No. S7-08-02...A Proposal with dangerous consequences...


        To:     Securities and Exchange Commission 
        Date:   April 29, 2002 
        Re:     Acceleration of Periodic Report Dates 



        To Whom It May Concern, 

        I have recently read of the proposed acceleration of the Forms 10Q, 10K and 8-K.  

        In short, I believe this is a proposal that should be rejected. 

        As a C.P.A. with several years of direct experience completing these forms and also 
		several years of managing staff personnel responsible for such filings, I have serious concerns on this proposal.  First, I have seen a significant growth in the requirements and breadth of what is needed in these forms over the past 5-10 years', and furthermore, I foresee 
no slowdown in the demands for inclusion of more data and lengthier discussion in the 10Q and 
10K, in particular.  Completing these forms in 45 days for the 10Q and 90 days for the 10K is 
a significant effort and fully requires the currently-allowed period of time.  It takes this 
amount of time to process the closing of one's books; gathering the needed data; preparing the 
daft Form; getting management input on the M,D&A; having management, outside counsel and 
outside accountants review the document; and the need for 1-2 days to actual perform the 
mechanic aspects of reviewing the electronic data before it's filed.  

        Attempting to properly complete the Form 10Q and 10K in a shortened period of time as required by the proposal would greatly increase the possibility of incorrect and/or incomplete reporting of these Forms.  There is simply not enough time for companies' staff and management 
to complete, and review thoroughly, all the sections of the Forms within the shortened time 
frame proposed by File No. S7-08-02.  If the substantial requirements of the Forms were to be 
scaled back, then the possibility of shortened reporting period is possible, but this Proposal 
makes no mention of that.

        In summary, the reporting deadlines for the Forms 10Q, 10K and 8-K should not be 
changed. 

        
        Sincerely, 

        Gerald Graves, C.P.A. (California) 
        Corporate Controller 
        Electronics for Imaging, Inc. (Nasdaq: EFII)