The ICI, in particular, urged the Commission to reaffirm the core principles of the mosaic theory - under which an analyst can assemble pieces of non-public and immaterial information into a mosaic that reveals a material conclusion. I hope that the Commission’s adopting release couldn’t be clearer on this point. We did, of course, make clear that we wanted to keep a clear path for analysis while blocking the path to the practice of distributing material nonpublic information to a favored few.

The Channel Checkers is in the business of collecting large amounts of immaterial information that we believe our clients can add to their mosaics to help them draw better more meaningful investment conclusions. We do five things that make us unique when compared to expert networks and other independent research firms: 1. We never pay anybody for information (experts are paid) 2. We never contact or speak to high level personnel.  All our contacts are with frontline field workers who do not hold material information. 3. We do not catalog our channel check respondents meaning we do not build recurring information connections.  We capture random connections with people, boosting the immateriality of each individual connection we make. 4. We do not offer investment opinions to clients.  We intentionally ask our clients to not even tell us what purspose our channel checking data will be used for. 5. 100% transaprency.  We allow clients to dictate where, when and how we collect our data. We believe that large scale, low level channel checks meet the demands of Regulation FD while also providing strong insight into business trends in the real economy.  We believe that by collecting large amounts of immaterial information, better investment decisions can be reached, without legal risks that are sometimes required when utilizing other forms of investment research. Please take this posting as an invitation to reach to me or our team to have a discussion about our methods for research or for ideas on how to accomplish your research objectives in light of current events. Thank you. Casey Ryan Managing Partner The Channel Checkers 415.786.2607