Press Release

10/31/05 – In the post-Sarbanes-Oxley era, pre-IPO companies have a host of new issues to address before they consider going public. At least anecdotally, we know that companies are preparing much more in advance of their initial registration and subsequent initial public offering. Compliance with Section 404 and the implementation of effective internal controls is one issue looming large for any company seeking to submit themselves to the rigors of being a public company.

We reviewed the Risk Factors section of this year’s IPOs to see what was lurking within the issuers’ disclosures regarding internal controls. To do so we surveyed the topic sentence of each risk factor as disclosed in the Risk Factor section.

In our survey of 2005’s 182 IPOs (through 10/24/05) there were at least 31% (57 of 182 IPOs in the period) which had specific risk factors concerning possible or real non-compliance with Section 404. Amongst those with such risk factors, we identified several major themes within the risk factors’ topic sentences. We categorized them as follows and give an example for each theme. We also compiled a list of infrequent risk factors for review.

Internal Control Theme

RISK FACTOR Sub-Section

Risk Factor Topic Sentence

Failure to Maintain Adequate Internal Controls

1^st of 2 Sub-sections:

Risk Factors Related to Our Company

27^th of 28 Risk Factors in Sub-section:

If we fail to maintain an effective system of internal controls, we may not be able to accurately report our financial results or prevent fraud.

Failure to Achieve & Maintain Adequate Internal Controls

1^st of 3 Sub-sections:

Risks Related To Our Business

33^rd of 34 Risk Factors in Sub-section:

Failure to achieve and maintain effective internal controls in accordance with Section 404 of the Sarbanes-Oxley Act could have a material adverse effect on our business and stock

price.

Future Loss of Confidence or Value

2^nd of 2 Sub-sections:

Risks Related to this Offering

9^th of 9 Risk Factors in Sub-section:

If we identify deficiencies in our internal control over financial reporting, our business and our stock price could be adversely affected.

General Sarbox Disclosure as to Possible Future Non-Compliance

3^rd of 3 Sub-sections:

Risks Related to the Offering

10^th of 10 Risk Factors in Sub-Section:

We may be exposed to potential risks resulting from new requirements that we evaluate our internal control over

financial reporting under Section 404 of the Sarbanes-Oxley Act.

Material Weakness

1^st of 3 Sub-sections:

Risks Related to Our Business

1^st of 21 Risk Factors in Sub-section:

We have identified material weaknesses in our internal controls, which could affect our ability to ensure timely and reliable financial reports and the ability of our auditors to

attest to the effectiveness of our internal controls.

May Not Be Considered Adequate / Effective

3^rd of 3 Risk Factor Sub-sections:

Risks Related to Our Industry

5^th of 10 Risk Factors in Sub-section:

Our internal controls over financial reporting may not be adequate and our independent auditors may not be able to certify as to their adequacy, which could have a significant and adverse effect on our business and reputation.

Internal Control Theme

RISK FACTOR Sub-Section

Risk Factor Topic Sentence

No Assurance

1^st of 3 Sub-sections:

Risks Related to Our Business

13^th of 20 Risk Factors in Sub-section:

We can provide no assurance regarding our, or our

independent registered public accounting firm's, conclusions

at March 31, 2007 with respect to the effectiveness of our internal controls over financial reporting.

In Development

1^st of 2 Sub-sections:

Risks Relating to Our Business

12^th of 27 Risk Factors in Sub-section:

Our internal financial reporting procedures are in development and we will need to allocate significant resources to meet applicable internal financial reporting standards.

If Unable to Implement

1^st of 2 Sub-sections:

Risk Factors Relating to Our Business

32^nd of 32 Risk Factors in Sub-section:

If we are unable to implement the requirements of Section 404 in a timely manner or if we conclude our internal controls are not effective in other areas, we may be subject to sanctions or investigation by regulatory authorities and incur additional compliance costs and the financial markets may react negatively.

If Unable to Improve

3^rd of 3 Sub-sections:

Risks Related to Our Capital Structure

4^th of 11 Risk Factors in Sub-section:

If we are unable to improve and maintain the quality of our internal controls, any weaknesses could materially and adversely affect our ability to provide timely and accurate information about our company, which could harm our reputation and share price.

Not Yet Evaluated

1^st of - Sub-sections:

Risks Relating to Our Business and the Ophthalmic Industry

18^th of 18 Risk Factors in Sub-section:

We have not yet evaluated our internal control over financial reporting in compliance with Section 404 of the

Sarbanes-Oxley Act.

Past Deficiency / Effect of Future Deficiency

1^st of 4 Sub-sections:

Risks Related to the Acquisition of [Company Name]

12^th of 13 Risk Factors in Sub-section:

We have in the past identified significant deficiencies in our internal controls, and the identification of any significant deficiencies in the future could affect our ability to ensure

timely and reliable financial reports.

© CCH INCORPORATED 2005. IPO Vital Signs includes all U.S. market IPOs, including REITs and non-U.S. headquartered IPO issuers, except for 1) closed-end funds; 2) best-efforts, self-underwritten, and direct offerings; and 3) IPOs filing under form SB-2 with an offering amount of less than $5 million. All fees are estimated and taken from Part II of the final amendment if not disclosed in the final prospectus.