In August, 2004, the SEC decided to release all comment letters free of charge, to expand the transparence of the comment process, and to have the information available to a broader audience. This program is an introduction to the SEC comment letter process, which will define the various types of comment letters and responses. The questions of “Why are comment letters important?” and “What are the various time constraints relating to the deals they involve?” will be addressed. Search techniques for searching for precedent in SEC comment letters will be explored.