From: Ron Smith [ronsmith@realtechnology.com]
Sent: Monday, January 06, 2003 11:51 AM
To: rule-comments@sec.gov; ALDye@HHLAW.com; aldmhd@bellatlantic.net
Cc: OsheroffM@SEC.GOV; bellera@sec.gov
Subject: File No. S7-52-02

To: Jonathan G. Katz, Secretary, U.S. Securities and Exchange Commission

RE: Comments on File No. S7-52-02, "Proposed Rule: Mandated Electronic
Filing and Website Posting for Forms 3, 4 and 5"

Dear Mr. Katz: 

I submit this letter in response to the request of the Securities and
Exchange Commission (the "Commission") for comments on its Proposed Rule
"Mandated Electronic Filing and Website Posting for Forms 3, 4 and 5". 

I am the developer of Romeo & Dye's Section 16 Filer software, which is
currently in use for Filing Forms 3, 4 & 5 on the EDGAR system. My
comments are largely technical in nature and focus on the new web-based
system (the "System") that is being proposed for submitting these forms.

1. Accessibility of New Web-based System to Third-Party Filer Software:
Because a web-based system will not be able to provide the functionality
present in current software systems used by Insiders, the Commission
should make the System accessible to third-party software. Specifically,
the System should allow third-party software to bypass any data entry
screens and upload the Forms directly, using a version of the Reduced
Content XFDL Specification currently accepted by EDGAR.  

The System should incorporate state-of-the art technologies such as web
services and SOAP to allow third-party systems to directly transmit
submissions, bypassing the need for a user to open his or her browser,
navigate to the correct location on the SEC's website, and choose the
correct file to submit.  By providing third-party software a method of
direct transmission, you will make the process of submission easier for
filers and less prone to errors.

2. Data Format of Forms 3, 4 and 5
The current EDGAR system will allow forms to be submitted in a variety
of formats, subject only to a few formatting rules.  While this makes it
easier for a filer converting a form from a word processing document,
the end result is that electronic forms currently being submitted to
EDGAR are not in a uniform data format- they merely mimic a paper form.
The data cannot be easily converted into databases or spreadsheets or
analyzed by common office productivity software.  In addition, because
forms are submitted in varying formats, forms filed by different
Insiders look very different online and many are difficult to read.

I strongly suggest that the Commission revise the Reduced Content XFDL
Specification to specify an XML data format for each form.  (The current
XFDL specification is XML-like, but does not specify the actual data
elements of the Form, only the filing information).  The format for each
form should be standard XML that encompasses all of the data elements to
be collected. The Commission should also develop a separate XSL style
sheet that will be used to format and display the corresponding XML
data.  In this way, by separating the data from the formatting, the data
can be consistently displayed on the SEC's website and also be easily
imported in to databases, spreadsheets, and other computer systems.  XML
and XSL is currently supported by most popular browsers and the XML and
XSL specifications are an Internet standard.

3. Data Entry in New Web-based System
The data entry portion of the System should allow for an unlimited
number of rows in each of the transaction tables. Filings created with
the data entry screens of the System should follow the same data
formatting outlined in item 2 above.

4. Availability of New Web-based System
The System should be available to accept filings 24 hours a day, 7 days
a week, all year long.  Although the Commission does not operate during
all of these times, the System can simply place the filings in a queue
and disseminate them at the next available window.  Providing this
flexibility will make it easier for Insiders to file on a timely basis
as they will not have to schedule their filings during the limited
period that the filing website is currently available.

I appreciate the opportunity to comment on the Proposed Rule. If you
have any questions or would like additional information, please contact
me at (206) 254-0995.


Ron Smith
Real Technology
www.realtechnology.com