From: Adam B. Glazer [glazera@sec.gov]
          Office of Regulatory Policy
          Division of Investment Management

On February 5, 2004, Tom Klaff of Surety, LLC. ("Surety") and Andrew Lowenthal and Lendell Porterfield of Van Scoyoc Associates met with staff members of the U.S. Securities and Exchange Commission to discuss certain issues relating to the Commission's proposed rule amendments concerning the pricing of investment company shares in Investment Company Release No. 26288 (Dec. 11, 2003). The following Commission staff members attended the meeting: Cynthia M. Fornelli, Deputy Director; Robert E. Plaze, Associate Director; Penelope Saltzman, Senior Counsel; and Adam Glazer, Attorney, Division of Investment Management.

Surety has created a software program, using secure hashing algorithms, that digitally time-stamps electronic records or transactions and enables independent validation of the authenticity of the records and transactions any time thereafter. The program also enables third parties to independently verify that an electronic record's time-stamps are unalterable and permanent, and cannot be forged.

Mr. Klaff described the uses for the software program, including the ability to time-stamp transactions and, independently and cryptographically, verify the integrity and sequence of the audit trail.