October 4, 2000

Stephen Cutler, Esquire
Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, DC 20549

Dear Mr. Cutler:

Our firm represents a number of smaller public companies that are attempting to deal with the Commission's new Regulation FD. We are assisting them in understanding the new rules and advising as them as to their requirements. Many of these clients do not utilize investor relations firms extensively, if at all, and many of them do not have in-house counsel. Accordingly, we are working to help educate company employees with varying non-legal backgrounds as to how to comply with Regulation FD.

It is our understanding that the Commission is considering a deferral of the implementation of Regulation FD from the current October 23, 2000, effective date. We believe that this would be a great help to our smaller clients. With additional time to implement compliance programs, re-train corporate spokespersons and others, and obtain answers to several unresolved issues, we believe these smaller public companies will better be able to comply with the new rules.

Thank you for your consideration of our comments.

Sincerely,

Gregory C. Yadley
Gregory C. Yadley

GCY/jaj