SecProbe.io

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May 2, 2005

Linda Van Doorn
Senior Assistant Chief Accountant
United States Securities and Exchange Commission
Washington, D.C. 20549

Dear Ms. Van Doorn:

We are in receipt of your letter dated April 20, 2005 regarding the Commission's
review of our Form 10-K for the fiscal year ended December 31, 2004. We
acknowledge that we are responsible for the adequacy and accuracy of the
disclosures in this filing. We acknowledge that neither your comments nor
changes to disclosure that we make in response to your comments foreclose the
Commission from taking any action with respect to the filing. We also
acknowledge that we may not assert your comments as a defense in any proceeding
initiated by the Commission or any person under the federal securities laws of
the United States.

Comment:
Your first comment was regarding Note 1 to the consolidated financial
statements, specifically item (d) Revenue Recognition, page A-10. You asked for
us to clarify the basis for the policy of recognizing revenue on the profit
sharing component "when it is reasonably certain that the managed company will
have an annual profit" and to clarify the term "reasonably certain". You
referred us to SAB 104 and EITF Topic D-96.

Response: We believe that our accounting procedure is the preferred method
called for in EITF Topic D-96, but that we should have more clearly explained
our application of that procedure. Our revenue recognition is based on the
profitability of our client. Using language from EITF Topic D-96, we do not
believe that it is appropriate to recognize revenue "...based upon the
probability of a factor being achieved." Again using language from EITF Topic
D-96, the method we are applying "...eliminates the potential that revenue will
be recognized in one quarter and reversed in a future quarter." We plan to
revise our disclosure in future filings to read as follows: The profit sharing
component is recognized in the fourth quarter, when it is certain that the
managed company will have an annual profit.

Comment:
Your second comment also addressed Significant Accounting Policies under Note 1
to the consolidated financial statements, specifically item (n) Recently Issued
Accounting Pronouncements, page A-15. You asked us to clarify that we evaluated
our variable interest entities to determine whether of not we were the primary
beneficiary and therefore whether or not such entities should be consolidated.
In addition you asked us what changes we would make in future filings to clarify
how we have considered consolidation relative to variable interest entities.

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Response:
Our footnote should have more clearly explained our position with regard to
variable interest entities. Rather than saying "We currently do not consolidate
any variable interest entities therefore the adoption of this standard did not
have a material effect on our financial position, results of operations or cash
flows", it should have said "We currently do not have any variable interest
entities therefore the adoption of this standard did not have a material effect
on our financial position, results of operations or cash flows." In future
filings we will correct this language and, should any of our entities become
variable interest entities or should we acquire entities that have those
characteristics, we will explain how we have considered consolidation relative
to them.

You may contact me at 512-314-4403 if you have questions regarding this
response.

Sincerely,

/s/ W.H. Hayes
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W.H.Hayes
Senior Vice President

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