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Re: None

Friday, 04/04/2014 5:09:55 PM

Friday, April 04, 2014 5:09:55 PM

Post# of 6440
New JOBS Act comment letters I submitted are now available here:

http://www.sec.gov/comments/s7-11-13/s71113.shtml

The Supreme Court ruling in McCutcheon v. FEC seems to me to be directly-analogous to the final Rulemaking for the JOBS Act. It would be surprising, in my opinion, if the SEC ignores this decision in McCutcheon and imposes any "aggregate limits" on investing by members of the general public in JOBS Act-compliant public offerings of unregistered securities from numerous issuers.

I see no meaningful difference between a contribution to a "political campaign" and a contribution to any "crowdfunding campaign" -- other than politics -- an equity/debt "return on investment" vs. some intangible "political" ROI. My expectation is the SEC's final Rules for Title II, Title III and Title IV will create fully-deregulated "crowdfunding" for equity or debt securities offerings or sales including advertising to the general public.

http://www.sec.gov/comments/s7-11-13/s71113-98.pdf

The forthcoming "testing the waters" pre-offering communications that will be allowed under Title IV of the JOBS Act will create an unprecedented degree of flexibility for issuers by imposing zero up-front costs for regulatory compliance. This will enable literally anyone in the United States or Canada to begin soliciting expressions of interest publicly from would-be investors, and then to follow up with regulatory filings to commence a securities Offering only after sufficient investor interest has been located.

These regulatory changes are an exceptional opportunity for our company, and for the growth of forensic social media which must provide not only a reliable, meaningful and trusted "public record" but must also provide cybersecurity and privacy safeguards in the cloud -- these are the PRECISE areas of expertise of our PivX/Homeland Forensics team and the PRECISE legacy of investment that we are building upon today with Public Startup Company. I am looking forward to sharing a comprehensive update with details on our progress and direction in the near future.