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U.S. Securities and Exchange Commission To the att. of Ms. Florence E. HAR MONSecretary 100 F Street, NE Washington, D.C. 20549-9303 USA Submitted via the website Brussels, 6 August 2008 Re: C omments on Proposed Rules Relating to the Usen teorfa cItive Data (XBRL or eXtensible Business Reporting Language) Release 33-8924 of May 30, 2008 - File No.: - 0S87 -11 Dear Ms. Harmon, 1EuropeanIssuers is submitting this letter in response to the srte qouf ethe Securities and Exchange Commission (the “Commission”) for comm eonnt s the Commission’s proposed rules discussed in Release 33-8924 of May 30, 2-008 File No.: S7-11-08 (the “Release”). The Release relates to the use of interactive odra tXaB RL (eXtensible Business Reporting Language) to improve financial reporting. Under certain conditions XBRL may enable standeadrd isdata processing including access/identification, analysis, presentation/comrispoan and exchange of financial and other information. Therefore, like other formatted alagnegs,u XBRL may facilitate the exchange and use of data and reduce the time to access dtahtoas.e However, EuropeanIssuers does not believe that ptohte ntial benefits of XBRL would justify any mandatory use of XBRL. At any rate, the ec oneoffmecits of using XBRL need to be further assessed over a period of time before ad amtoaryn and costly filing procedure could be considered. This should generally be done sine clo-operation with issuers ...
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