Regarding the first issue, the ICFR reporting, Enforcement agrees that Respondent cured the deficiency that had previously been identified but now criticizes the inclusion of a carve out of the ICFR reporting under Section 18. The Declaration of Hilda Garrett asserts that Item 308T, which permitted non-accelerated filers to "fumish" rather than file management's ICFR report, was applicable only through December 15, 2009. Garrett Aff. at 11 6. Her information is not correct. That rule was extended by the SEC on more than one occasion; the timing of the ultimate lapse ofthe rule is, at the least, unclear; and that language is still used in many filings. See, e.g.,. SEC Release No.s 33-9072; 34-60813; 33-8934A; 34-58028A. Further, had this issue been raised by Corporation Finance during the initial review ofthe filing, it would have immediately been addressed. The Company confirms that the language will not be included in future filings. Regarding the DCP issue, the same language used by DBMM is used by any number ofother filers including Microsoft. The language used by DBMM has never before been identified as deficient, the SEC's ·suggestion of other language does not render the filing deficient, and the filings will be revised pursuant to that comment going forward.
Glad you agree. SEC never wants anyone to believe they could be wrong, referencing DBMM. Their stranglehold on the Stock community is absolute so they don't want any belief otherwise. This is one that challenged and made them loose some credibility, so YES, they absolutely want to bring down DBMM. Easy to see. DBMM
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