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November 18, 2004 Mr. Jonathan G. Katz, Secretary U.S. Securities and Exchange Commission 450 Fifth Street N.W. Washington, D.C. 20549-0609 Re: File Number S7-35-04 Dear Mr. Katz: PricewaterhouseCoopers LLP appreciates the opportunity to comment on the Securities and Exchange Commission’s (the “SEC”) Proposed Rule: XBRL Voluntary Financial Reporting Program on the EDGAR System (the “proposed rule”). We commend the SEC for its proposal to enable registrants to voluntarily submit supplemental tagged financial information using the eXtensible Business Reporting Language (“XBRL”) format as exhibits to specified EDGAR filings under the Securities Exchange Act of 1934 (the “Exchange Act”) and the Investment Company Act of 1940 (the “Investment Company Act”). We support the SEC’s approval of the proposed rule. Further, we believe that the program can and will be enhanced by collaboration of market participants, including the SEC, in the development of appropriate taxonomies, software applications, and other tools that will continue to enhance the production, consumption and analysis of information contained in business reports. We have provided our answers to the questions included in the proposed rule and respectfully submit them to the SEC for consideration. PwC participated in the XBRL-U.S. Adoption Working Group (the “group”). Combined commentary on this proposed rule was ...
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