If applicable a copy of the escrow agreement should be filed as an exhibit. Jurisdiction of offering With respect to utilizing the Internet or other electronic delivery means, your attention is directed to Commission Release No. Please advise if the Company intends to contact additional potential investors by direct e-mail solicitation. Supplementally, please advise whether or not the e-mail invitation will comply with Rule 134 under the Securities Act. If not, please explain the basis for this procedure under Release No. 33-7233 .
Reference is made to the discussion in Release No.
With respect to the electronic marketplace service, the Company should be aware that any direct or indirect securities activities that the Company may engage in may subject it to appropriate registration and other federal and state securities law considerations. Please advise us, supplementally, of the Company's intentions in this regard. Plan of Distribution Please identify by name and relationship to the Company each person who will offer and sell the shares on behalf of the Company. Such information should be presented on the cover page. Please advise, if the persons offering the securities on behalf of the Company will rely on the safe harbor from brokerdealer registration set out in Rule 3a4-1 under the Securities Exchange Act of 1934.