Commissioner Roel C. Campos, U.S. Securities and Exchange Commission
Thank you, Chairman Cox. I'm also pleased to support the final rules regarding foreign private issuer deregistration, and I'd like to congratulate John White and his staff, particularly Mauri Osheroff, Paul Dudek and Eliott Staffin, for their fine work, as well as Ethiopis Tafara and the Office of International Affairs, and the Office of General Counsel.
In summary, this is an excellent rule. While you can't satisfy everyone all the time, this rule certainly will please nearly everyone this time. As evidence of this, we don't need to look much further than the comment letters, which were uniformly and vigorously supportive of the trading volume test. Moreover, I believe we were responsive to the few significant comments that we did receive on the reproposal. As has been noted, I definitely think it was the right decision to use worldwide trading volume in the denominator. Similarly, it makes sense to permit the inclusion of off-market transactions when calculating worldwide trading volume.
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