John -

I apologize for the delay, earnings release had us swamped!

After discussing the SOP with our expert partner network in Chicago, they
said they believe that this SOP has a 50-60% chance of passing.  Definitely
not a slam dunk.  That group gave me some general guidelines that are
helpful when responding to the standard setters:  stick to the current
literature (other authoritative literature that contradicts/supports your
position), cost vs. benefit analysis of implementing the new rules,
usefullness of new information required by the new standard to the reader,
and try to stick with the facts and try not to be negative (i.e. "we don't
like it" type statements).

We are still drafting the official Firm position on the SOP.  However, we
generally agree with the concept that accounting for PP&E/Depreciation
should be consistent and comparable between companies.  Please note, that I
am not trying to persuade you to support the Firm's preliminary views,
rather trying to make the letter more effective when AcSEC reads their
letter.

My comments are on the draft letter attached, with my suggestions and
comments in yellow.  Call me if you have any questions.

Heather

(See attached file: INGAAResponse - draft.doc)
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