There was a consensus in the comments to my post on General Solicitation the other day that I should submit my comments to the SEC.
So I did that this morning. My comment has not been posted publicly, but I suspect it will at some point.
This is what I said:
It is my opinion, and that of those who we do business with, including our securities lawyers, that these proposed rules effectively make General Solicitation a non-starter for startup companies. If the SEC's intention, with these proposed additional rules, is to neuter General Solicitation to the point that it is legal but nobody avails themselves of it, they will succeed.
The full blog post is here along with 138 comments at this time
http://www.avc.com/a_vc/2013/08/some-thoughts-on-the-secs-rulemaking-on-general-solicitation.html
Fred Wilson, A Venture Capitalist