Comment 3 Don Anders

To: International Valuation Standards Committee From: Don Anders, ASA Wipfli CPA’s and Consultants Milwaukee, WI USA October 2007 Re: Comments to IVSC Discussion Paper- Determination of Fair Value of Intangible Asset for IFRS Reporting Purposes- July 2007 To The Committee; I commend your efforts and admire the progress you have made to date to provide a common sense standardization of principles and to converge various counties accounting pronouncements in this subject matter. I would encourage you to make a fresh start and not be influenced by legacy pronouncements and precedent that has evolved from a patchwork of pronouncements on the subject of fair value and intangible assets. You should not be obligated to reconcile past IFRS or FAS with this current one. I would encourage you to be swayed by valuation principles and not accounting principles or precedent. My comments by your paragraph numbers are: 2.1.1 There is a great need for guidance with respect to valuation of intangible assets 2.1.2 The guidance you are proposing is at the right level of detail – except perhaps with too much information on relief from royalty benchmarking in 6.27-6.43. 2.1.3 When you complete your task, I think the document will be very valuable to the valuation industry. 2.1.4 I believe that a technical paper follow up can help to create a trail of updates and add clarity as the principles evolve and questions arise. 2.2 – 2.7 I applaud your ...