From: Paul Keller [pakeller@msn.com] Sent: Wednesday, March 31, 2004 9:20 AM To: rule-comments@sec.gov Subject: S7-19-03 The rules must change and there are even more significant changes that should be proposed. May I suggest you consider more sweeping changes. If you up the stakes I believe you will find more support for nominal change when the stakes are raised to higher levels. Please remember the forces arrayed against you are children of the situation ethics crowd that can and will do anything in their own interest. If you want some suggestions for further measures just e-mail me Paul A Keller