Monday, May 25, 2015

Social Media Rationale & Tips for Investor Relations / Corporate Communications

The Social Media conversation is taking place across all aspects of corporate and investor communications and seems here to stay.  After nearly a decade of direct engagement in investor relations social media communications, the Catalyst team's view is that companies cannot afford the luxury of ignoring this conversation, and some level of engagement makes sense for all companies - today.

The question is not if you will become engaged in social media, the question is when and how you will engage and how those actions will reflect on your company, its management team, industry position, crisis management abilities, and credibility with your various stakeholders. 

From an investor relations standpoint, social media has been treated like an electrified "third rail" fraught with danger and to be avoided at all costs.  The last study we saw said that roughly 70% or more of IROs stated they are not engaged in social media and have no intentions to do so. Given the extent to which legal concerns have been defanging effective investor communications over the past decade, this conservatism is not surprising. 

What is surprising is the extent to which the IR community continues to justify its lack of social media engagement by looking inward - principally at peers and others that have not yet ventured into the water. Using tepid levels of engagement as a yardstick, much of the IR community still seems comforted that abstinence is an appropriate strategy, a position that is often validated by counsel and others who are not judged by metrics of investment community engagement.

Catalyst takes a pragmatic approach to assessing the value of Social Media for Investor Relations and corporate communications: What value can it deliver for our clients? With what investment of time and resources? With what risks or opportunity costs.

From a risk standpoint, we are comforted by the SEC's clear support for the use of social media to disclose material news. While Catalyst does NOT advocate social media play the lead in this important role, but rather as a supporting channel to more traditional methods, the SEC's guidance on the topic provides clarity and regulatory cover for companies to engage in reasonable social media activity.

So why should you engage in social media for IR purposes?


1) To ensure your messages are clearly and regularly conveyed within the existing dialogue going on about your company anyway - rather than to keep your head in the sand to ignore the conversation.  (Do a search on Twitter or StockTwits or SeekingAlpha to see what is being said about your company.)  

Are you satisfied with the portrayal? The balance of fact and opinion? The accuracy of data provided? The nature of those engaged in the conversation? Would this dialogue be enhanced by a regular stream of fact-based messaging from your company pointing to your formal disclosure activity and reinforcing your strategy, goals and progress while also drawing attention to your IR communications efforts/opportunities?


2) To get your story in front of new investor, customer, partner & media eyeballs for the first time, or to remind those who have forgotten about you or are not thinking about you, to take another look. 

We find this to be the most compelling reason for social media engagement and here's why:

If you think about conventional corporate and IR communications, they consist of news releases and SEC filings tied to your name and stock symbol. They are pushed out electronically to a broad variety of financial databases & media sources where they are referenced and searchable typically based only on your name and stock symbol, and in some cases your industry segment.  

With over 10,000+ companies and likely 1,000s of communications per day - there is much for investors and databases to wade through.  Few investors have the time to watch a stream of headlines run by in the hope of discovering a compelling investment idea (which gets us to the importance of your headline (represented as a hyperlink to the release) , but that's another issue where we also have very strong opinions in conflict with the status quo!).

SOCIAL MEDIA HELPS REACH INVESTORS THAT HAVE NEVER HEARD OF YOUR COMPANY OR STOCK SYMBOL or have forgotten about you.  Unless you are Walmart, Google, Exxon, etc., your news will likely not rise to the surface in media or other coverage that investors might encounter without searching for it. 

Instead your news will be neatly filed in what we think of as "digital drawers" identified only by your name and symbol. Only those investors who own or follow your stock will ever see your news, unless something is done to get that days news and your Company exposure OUTSIDE of your digital drawer.  

Exposure of your Company and news "outside your digital drawer" is where we see value in social media engagement. Through social media postings you have the ability to get your news flow in front of investors, traders, media, bloggers & social media participants, often for the first time. This is accomplished through careful messaging + proper referencing of your news to industry topics, peer companies and social media sources, so that those tracking certain subjects or companies will come upon you and your story.  Given the vastness of social media activity, this process does take time, but we have found that you can build an audience for your company and investment thesis with new investors, one person at a time.  For small cap and microcap companies in particular, such progress can be quite meaningful. 

Via social media you are also able to build a base of participants that you follow and many will begin to follow your company as they discover you and find that your business and outlook are of interest.  We can think of no more cost effective way to add new relevant followers to your base of investment interest. 

The only cost is the time you expend to develop social media posts and to engage with those you identify. It can take just a few minutes or as much time as you care to devote to it, the decision being made based on the value you see from the effort. 

3) To demonstrate proactive communications and engagement to a variety of stakeholders.  Being active in social media makes a statement, just as being invisible makes a statement. Your communications posture and engagement are integral components of your corporate and IR brand - they speak to the values and goals of the management and board. 

While an oft heard critique of social media in the IR realm is that institutions are not paying attention, are not relying on it - more and more research shows this is not the case and report on the extent to which the influence of social media is growing amongst institutional investors. A recent poll we read suggested ~40% - we'll correct the number if we are wrong - of institutional investors rely on some aspect of social media in their investment process. 

That Bloomberg has built an analytical tool based on Twitter activity and that major financial portals and online brokerage firms have incorporated social media feeds into their investor dashboards suggests this medium is relevant and here to stay. Much of this activity is linked to "sentiment" indicators derived from social media activity. This begs the question, as an IRO are you content with having your Company's investment sentiment indicators solely influenced by an unwatched bunch of strangers? Similarly, are you able to support the position of not entering the conversation and not seeking to ensure that these sentiment measures reflect both the facts and your Company's view? 

Finally, social media also appears to be a community effort with a "one hand washes the other" dynamic. Raising the profile of other's posts and news, over time, should increase the likelihood of their seeing your content as well as their reciprocating in some constructive fashion. A community of individuals shows up each day to expand the visibility of their narrative - and by participating and sharing in that process you are able to benefit from the same.


4) To expand media & online exposure and coverage of your company.  Many top journalists for print, TV, radio and online outlets, as well as industry trade press and bloggers are active in social media. This presents another great opportunity to build awareness of your company and your news flow while also garnering a window on what they are thinking.  


5) To protect your brand and put in place a credible information conduit in the event of crisis.  If you haven't staked your social media turf, someone else might do it for you, with alarming consequences.  Fake accounts, spoofs, etc. are more likely to happen if you have not established known and trusted social media accounts with a history of activity that investors can rely upon as being "official."  Social media can be a hugely valuable conduit of information to all stakeholders should your company experience a major crisis or challenge, including website, power or telecom outages.

These reasons alone make taking initial steps in social media engagement a no-brainer.  The risks of engagement in our experience over many years are limited relative to opportunity cost of not-engaging, particularly as social media evolves (and we grows in influence) over the next few years.  

Those not engaged seem to bet on social media being a fad that disappears and makes them look prescient.  We have no crystal ball, but based on what we've seen, we are confident that is not a likely outcome.  However, we also admit that social media will continue to evolve to meet the needs of those who are engaged and for that reason any effort much remain flexible and open to change.

We recognize that social media seem scary to those who are not experienced in the practice, particularly Boards and C-suite executives that are responsible for setting the non-social media path. We are concerned the recent Twitter disclosure debacle is being used to justify the the "just say no to social media" posture, though as an isolated and easily preventable incident it does not seem a reason for companies to keep their heads in the sand. 


Catalyst Global is Here to Help
In our view, the risks of modest engagement on the IR front are limited if you follow a well thought out plan. We also believe it will be increasingly hard to defend a "head in the sand" social media posture. Getting engaged and informed on what it is and how it can help you is the best offense and defense.

Catalyst's social media focus is to provide counsel and support for companies looking to take the first steps into social media for IR.  We have been actively engaged in social media in the investor relations and corporate communications space for over nine years and through those efforts we have developed a solid base of understanding of the medium and how it can be harnessed for expanding IR visibility and IR community support.

Our role is to help you understand the value of the effort and to help you formulate a path for initiating an IR social media presence.  Our preference is to provide the counsel and guidelines to support Companies building their own in house efforts, and from there we are able to provide ongoing oversight and advice as requested. 

Social media is NOT an IR PANACEA, but particularly for smaller companies that are not the subject of active media or other coverage, social media can deliver exposure you otherwise could not develop.  And there are metrics you can track that demonstrate a growing base of engagement by investors, media, bloggers, traders, industry groups and partners that will help you justify the effort.


Social Media Tips 

For those already engaged in social media in some fashion, we offer a few social media tips to which we may add others going forward...


Create an IR-Specific Social Media Presence - Because investor relations information and perspective is often different than normal corporate, sales, marketing or other company communications, we believe your IR social media efforts should be conducted in a separate account that is clearly noted as being for IR use.  Our practice is to use "IR" as the suffix for such accounts and we see others doing this as well.  Of course corporate and other accounts can support each other and share similar messages as circumstances and strategy suggest.  Leveraging consumer or industry awareness to introduce an IR opportunity can make a lot of sense for some companies. 


Use Stock Symbol References - Stock symbol nomenclature was started at StockTwits and later adopted by Twitter and other sites.  In most IR related posts, you should append a dollar sign ($) prefix to your stock symbol as in: $IBM $GOOG, $AAPL. The $ identifies a stock symbol, creating a searchable reference for investor-related posts.  While you can search a symbol without the $ sign, it will yield a good deal of non-relevant material, not a focused set of stock related data.

As an example, the post below used #MUX to denote the stock symbol rather than $MUX. As a result, those searching for news on $MUX would not find this or other Company posts. 


Searching on #MUX will yield posts on a variety of non-stock topics including a home delivery service in Pakistan! 



This hold true for posts relating to public company partners, customers or even industry peers; make sure to use the $ approach. In our experience, posts that include multiple stock symbols, properly referenced, achieve several fold greater visibility and engagement those with just one client symbol.

Social Media Sharing Functions  - This is a simple but often missed visibility enhancement for both the entity who's content you are "retweeting" or sharing as well as for the subject of the retweet/sharing.  If it's your website's retweet function, you should reprogram it to enhance the reach of the retweet activity for your social media posts.

We'll use Twitter as the example for what we mean, but it's relevant with other social media services.  The problem is that often when you click on the "share" button to retweet or share a social media post, the social media "handle" or account name for the source of the post is not properly identified with their searchable social media name (which in the case of Twitter is signified by the prefix "@" as in @CatalystIR NOT CatalystIR NOR #CatalystIR)

To share the following trade publication article via Twitter to highlight further industry demand for fingerprint biometrics in support of a client...

Zwipe collaborating with Danish Bank on biometric credit card http://www.biometricupdate.com/201505/zwipe-collaborating-with-danish-bank-on-biometric-credit-card 

We clicked the Tweet button to share on twitter and here's the text the site's share function provided:



The Tweet function failed to include the source's proper Twitter "handle" @BiometricUpdate and instead provided "BiometricUpdate" (without the Twitter @ signifier that creates a hyperlink to the source's Twitter account). This reduces the visibility and interactivity of the post for both the source and the reTweeting party. 

Catalyst revises the automated text to include the correct @____ handle while adding appropriate $stock symbols and keywords to optimize the post for greater visibility and referencing.

Autoposting - In an effort to streamline workflows and time investment in social media, some companies rely on social media "auto-posts" of their news announcements or SEC filings. Such posts are created automatically but can vary in their effectiveness.  The auto-posts at issue tend to provide little or no relevant information to help readers understand nature the post or the posting entity and/or why the reader should "click through" to read the post. 

Often it's just a mysterious hyperlink with little or no information.  Such posts often fail to include a stock $ymbol reference and lack any hashtag references that would help position the post in front of those with relevant interest.  

At their worst, such auto-posting provides virtually zero assistance while demonstrating a lack of appreciation for the intended audience or their information needs which could even prove damaging to investor relationships over time. 

Auto-posting functions via email programs like ConstantContact and some of the newswires create posts based on your press release copy, however you should always review the proposed message and revise it to optimize its efficacy.  

Pictures and Video - Where possible, add pictures or video to your social media efforts to enhance your communication and to attract more attention.  Scroll down the postings on StockTwits and you will see how much an image expand the real estate of you post and helps to attract attention.  While the image function seems focused on stock charts, any photo will work. 

StockTwits Syndication - StockTwits is a "Twitter-like" social media service catering specifically to investors. It provides a targeted audience for IR efforts (though the site does seem to skew more to traders than fundamental investors) and pioneered the $ stock symbol nomenclature mentioned above.

Companies pay a modest fee to established a validated corporate account so that investors can be certain that the messages are coming from a Company's IR team or they can just establish a no-fee account. 

Beyond the visibility you can achieve on the site yourself, StockTwits content (including the posts that you make) are distributed / syndicated as a feed into other financial portals including those referenced below (though the list does seem to change as relationships come and go).  




We posted the following "Twit" (that's how we differentiate from a "Tweet") on behalf of our legal technology services client, Epiq Systems ($EPIQ) and is visible on Epiq's CNN Money news page (as would anyone else's post...). This feature allows you to get your message in front of a broader audience outside of your normal wire service and Edgar-based communications/disclosures. For that reason, we generally originate messages on StockTwits and then link that account to the Twitter account so that by posting one message you reach both channels. 



To Tweet or to Retweet There's a Difference - My colleague Tanya Kamatu taught me another Twitter trick just today that relates to using existing Twitter user "handles" (that's what I call their account name that starts with an "@" sign such as @CatalystIR our firm's Twitter handle) as part of your post. While this is not IR specific, the reach of your comment can be substantially limited if you don't understand how things work on Twitter. 

If you post a comment that starts with a Twitter handle, that Tweet will be treated by Twitter as a "retweet" and therefore not seen by the broader Twitter audience but only by those who follow both your account AND the @account that started your Tweet.  To combat that limitation, you can place a period before the handle, as in .@Account - and then the comment will be seen broadly.  This is only the case when the Twitter handle is the first element of a post, not when it's later in the post.  For more information on this topic visit thesocialu101.com 


With that, I thank you for your interest and encourage you to get back to your own social media efforts or program evaluation. Catalyst remains bullish on the potential of this medium to support greater IR visibility over time, and we are eager to counsel companies on how to enhance or initiate a social media effort that adds value and mitigates risk. 

Contact us if you are interested in learning how we can be of help. 

Best regards,


David C. Collins
Managing Director
Catalyst Global LLC
212 924 9800 






P.S. Our thanks to Tim Human and the IR Magazine team for publishing our social media tips today.  We appreciate the added exposure for some small things that can help IROs learn how to navigate the potential of social media.  
The tips are found here: http://www.irmagazine.com/articles/social-media/20887/social-media-tips-catalyst-global/

Monday, March 24, 2014

IR Magazine: Should You Pay for Equity Research


Should you pay for equity research?


Sell-side cutbacks have left more companies contemplating issuer-sponsored equity research. But not all providers are equal
As many companies know through painful experience, a lack of research coverage is a serious impediment to attracting new investors. Without it, investors may view a business as unvetted or too difficult to value. 
View the balance of the article, in which Tim Human included some of our thoughts, here: http://www.irmagazine.com/articles/sell-side/20098/should-you-pay-equity-research/
Additional thoughts: We would argue that issuer-paid research is no more biased than most sell-side research which is provided by investment banks that have raised money for the subject company and/or hope to secure other fee income from banking, M&A or other advisory work. No one shows up to Wall Street to work for free. Everyone has some sort of agenda. 
Other key benefits of such research is that it can provide forward earnings estimates - in major earnings estimate services like First Call - for Companies that have little or no formal research coverage and therefore have no estimates or estimate consensus. Such estimates are helpful to investors who are screening for stocks or taking an initial look at a company - it helps them gauge the growth rate and efficiency of the organization. 
The other benefit is helping to bring disparate information all into one place - financials, management comments and strategy, recent releases, industry valuation metrics, competitive and industry factors, and valuation parameters. It's 'Cliff Notes' for equities. I expect that investors will do their own work to analyze and value the Company - but this research helps get you their radar screen.  It's principal benefit is in idea generation.
Lastly, as there could be alleged some aspect of "implied endorsement" when a company distributes a report that has been written on them - this concern makes most companies refrain from distributing either sell-side or company-sponsored research reports. Given this dynamic, the distribution channels the research provider brings to the effort are particularly important. If a research report is issued in the forest - few will read it without some proactive intervention.  Finally, 'marketing' a research report is also very important.  That helps connect all the dots - putting the Company and management together with the report and the investor - to ensure that the analyst and/or PM really focus on the story.  It's a multi-step process leading up to actually getting an investor engaged in a new story. 
Our thanks to Tim Human for raising this important issue - and showing how different times may require different measures.

Monday, January 13, 2014

Social Media – Leveraging Existing IR Assets to Attract New Eyeballs

In April 2013 the SEC made a bold, progressive step in condoning social media for Reg. FD compliant disclosure. IR professionals must now figure out how or if to follow that lead.

While 70% of IROs report NOT using social media, we believe engagement will grow as precedent mutes legal concerns and the benefits become better understood. In our view social media enables more frequent and granular investor dialogues fostering greater understanding through additional data, anecdotes, perspective or review. It can also play a key role in crisis communications, provided the channel is established well in advance.

But the most compelling argument for IR social media is that it provides an easy low-cost way to leverage your investment in existing IR assets, putting them before new investors, bloggers & media with similar interests. It’s no panacea, but over time builds a growing base of awareness and interest that can favorably influence your stock price. To be fair, the potential benefits of IR social media seem more compelling for smaller companies who struggle to develop investor interest against market currents that favor size and liquidity.

The Myth of Non Engagement
For now, social media’s importance to IR seems a near-sighted measurement of investors NOT engaged in the medium by similarly positioned IROs. Yet a brief visit to StockTwits, SeekingAlpha or Twitter confirms existence of a sufficiently large and growing audience to warrant our attention. Social media has also been validated by hedge funds who filter it to guide investment decisions, by Bloomberg’s integration of Twitter feeds into its financial information platform, and lest we forget, @Carl_C_Icahn, who’s 59 posts to date have drawn enormous Wall Street attention and 123,000 followers.

Your Company is likely the subject of an active social media dialogue that is shaping investor perceptions without you. 

And guess what? Your Company is likely the subject of an active social media dialogue that is shaping investor perceptions without you. Doesn’t it make sense to balance those communications with approved company messages?

You’ve got my attention; What would a social media IR program look like?
Because social media is an adjunct to your existing IR communications, the same disclosure rules and regulations apply. Despite the SEC’s comments, we do not recommend using social media to initiate material disclosures and our comments reflect that posture. However, we do recommend following the SEC’s guidance to publicly state which social media channels you use for investor relations, thereby protecting your social media efforts.

A formal social media program and plan should be developed along with policies and designated persons for the review and posting of messages and responses. This policy should be reviewed by management and counsel and updated at least yearly for any changes in practice, participants or approved social media forums.

Leading IR social media forums include Twitter, SeekingAlpha, StockTwits, SlideShare, LinkedIn, Facebook, Boardvote and Stockr. To reflect the unique needs of investors, public companies should establish standalone IR social media accounts. The “IR” suffix is frequently used and easily differentiates IR content from other social media communications (ex.  @CompanyIR).

We recommend using the same account name across all channels if possible. There is no cost to set up most accounts, though it does take some time to create a professional profile and presence. Protect account access by using strong passwords and 2-step authentication. Once set up the posting of approved messages takes just a few minutes and will become an  automatic part of your communications work flow.

But what are we posting? How do we maximize our success?
Social media is a “force multiplier” for the visibility of the IR communications and collateral you work so hard to create. Most of it has been disclosed on the wire or via Edgar and is available on your website or those of other organizations, making it easy to provide direct links. Thus, much of a basic program can merely involve providing links to IR collateral.

IR Social media content can include:

·      News releases, call transcripts & SEC filings
·      Presentation and conference call alerts
·      Presentations, webcasts & videos
·      Media coverage, interviews, blog posts & social media
·      Product brochures, photos & web pages
·      Research or other industry or governmental reports or white papers.
·      And a range of custom content we’ll save for another article.

Unlike financial portals where content is .... hidden ... based on stock symbols, social media is an unstructured fire hose of information... rationalized by key words...

Links to this content on their own, however, have little visibility or value (though we see them all the time) without a clear introduction. Unlike financial portals where content is safely ordered (and hidden) based on stock symbols, social media is an unstructured fire hose of information. That data glut is rationalized by key words or “hash tags” and stock symbols. In addition, “Follower” and “Followed” functions allow users to filter the torrent down to subjects of interest.

Each post must make clear what content is being referenced and why it is worth viewing. Assume it is the reader’s first interaction with your Company. Keys to successful posts include:

1)    Write clearly and succinctly, to be understandable to anyone. It takes time to winnow a message into 140 characters. Abbreviations and informal style make this possible.

2)    Use appropriate stock symbol nomenclature (generally a $ before the symbol as in $GOOG) so that all your posts are referenced to your symbol. Credible use of other relevant stock symbols will also aid your post’s discovery.

3)    Use “hash tags” as they are known on Twitter to reference your post to topics of interest searched by investors, such as #healthcare, #energy, #Japan, #timber & #retail. Use the most popular hash tags but also experiment to reach a different audience. Hash tags position you for discovery by those who DO NOT know your company or stock symbol. This is our primary reason for IR social media engagement.

4)    Link your accounts so that a post to one will automatically syndicate to others. But read the fine print to optimize your visibility by originating posts on certain sites and syndicating them to others. Be careful, some sites let you delete posts; others do not.

5)    Twitter averages 500M tweets per day across all topics, so even after a few days, a search might not yield your post. To unbury your post, delete and repost it (our recommendation), alter or add a photo or video and repost, Retweet, comment or favorite it.  

     Below are examples of social media posts on StockTwits. The top set of posts shows normal text posts and the following three examples show how the posts cut through the clutter better with the use of a graphic (photo, chart, etc.).


Showing our client's lithium replacement
 battery aboard an electric fork lift.

Showing our client's diagnostic device in action.

Highlighting our client's CEO and his Twitter page. 


We hope these comments have taken some of the mystery out of social media for IR - and how it can be easily implemented - and provided some valid reasons to reconsider your reluctance to enter the fray. We look forward to your comments and questions.

David C. Collins
Managing Director
Catalyst Global LLC – Capital Markets Counsel
January 13, 2014


Wednesday, December 11, 2013

Response to IR Magazine's Question - Does IR Need an Overahaul


Does IR need an overhaul?






The following are our thoughts on the issue Laurie Havelock raised in IR Magazine.  


We are a bit slow to the discussion, having only seen this article today.  YES IR needs an overhaul, but we don't think it's IR as much as the highly conservative, restrictive environment and fear mongering that limit us in trying to communicate what's going on to the people who own the companies we work for.

Fear of class action litigation, SEC reprisals and a strict adherence to the status quo (the Company's or its peers) cause far too many companies to pull their communication heads into their shells.  No amount of leadership or innovation in the IR role can overcome a C-suite that abrogates its responsibility by following the advice of its counsel and auditors to take the safe route, admit no problems or concerns, make no projections and to say little or nothing of real value to guide those who own the Company. Our function has become "disclosure" rather than "communication" and yet IR practitioners have very little power to overhaul the framework to improve our ability to speak freely about what's going on. Every aspect of business involves risk, and generally the riskier the initiative, the greater potential value it may create. We view good management as needing to listen to all of its advisors and then make decisions that make the most sense for the Company, not decisions that eliminate risk.

As counselors who work on retainer, we can't help but notice that the most influential people in what becomes the "final word" on strategy & communications are IN NO WAY measured, judged or compensated in relation to the creation of shareholder value. Unfortunately and cynically, their compensation in reviewing communications is in direct proportion to the extent of their edits. Yes, there are many fabulous, pragmatic attorneys and auditors – who do understand what IR is trying to achieve and will accede to a strategy that involves some nominal amount of risk in an effort to enhance the potential reach and success of a communication and an overall program.

To illustrate how bad things really are, most companies are even fearful of using quantitative measures or abbreviations in their headlines, such as "XYZ Q3 Revenues Rise 15% to $525M on Strong Widget Demand in Europe." We have submitted headlines like this - which are intended to differentiate the Company and draw in new investment interest, only to have them lobotomized into "XYZ Allied United Industrial Corporation Reports Fiscal 2013 Third Quarter Financial Results of Operations for the Periods Ended September 30, 2013."  Not only does it say little - it take more of an investor's precious time to slog through the formality. 

And the people who denied the first version and insisted on the language of the second got paid by the hour to homogenize any semblance of communication right out of the release. Their fear, as we have often heard, is "what do we say if revenues are down next quarter? We must be consistent quarter after quarter." That fear makes us unable to communicate about what's going well because of some vague fear that a negative event occurs down the road that will force the Company to publicly discuss it - as if investors wouldn't notice if we didn’t put it in the headline!?!  Does the SEC insist that our headlines be uniform?  Is a headline considered a standalone disclosure or does the body of the release count?

The same fears keep us off of social media and prevent us from sharing analyst reports or estimates because of the danger of implied endorsement. The same fears force us to use overly wordy and qualified sentences (do we really have to qualify that the quarterly comparison is versus the prior year’s period when a full P&L is provided in the release? Our view is that year over year is implied, anything else needs to be clarified.) These fears also prevent us from taking full advantage of the safe harbor protection. To we really need to clarify to investors that things might turnout differently than we currently expect – that we had a one-time, non-cash write down of our crystal ball to reflect the end of its useful life?

The same legal strictures force us to spend a lot of extra time and money in every release to reiterate our risk factors, but then leave us to worry if our other utterances are similarly protected.

In seeking to protect investors and provide clarity - we seem to have done the opposite. We are damaging the public company’s communications function, limited what information can be provided, and ratcheted up the costs in an effort to try to stymie the minority of players with evil intent. Probably the best way to reboot IR would be to reform our securities laws and liability - so that a good faith effort to communicate is an asset not a liability and that investors be given some semblance of responsibility for knowing what they own, reading our disclosures and understanding that nothing in life is completely predictable.

A lot is at stake in this question in our view, the costs and challenges of being a smaller public company have grown increasingly burdensome at the same time Wall Street – both the sell-side and buy-side – has been moving away from supporting such companies. Yet small companies have long been the font of job creation. Yes we need to overhaul IR and a good deal more.