DATES: Effective Date: November 15, 2010

Compliance Dates: November 15, 2010, except that companies that qualify as “smaller reporting companies” (as defined in § 17 CFR 240.12b-2) as of the effective date of the rule amendments will not be subject to Rule 14a-11 until three years after the effective date.

As of Nov 15, 2010 (the compliance date) we were not a smaller reporting company

Exchange Act Rule 12b-2. A smaller reporting company is defined as “an issuer that is not an investment company, an asset-backed issuer, or a majority-owned subsidiary of a parent that is not a smaller reporting company and that: had a public float of less than $75 million as of the last business day of its most recently completed second fiscal quarter, computed by multiplying the aggregate worldwide number of shares of its voting and non-voting common equity held by non-affiliates by the price at which the common equity was last sold, or the average of the bid and asked prices of common equity, in the principal market for the common equity; or in the case of an initial registration statement under the Securities Act or Exchange Act for shares of its common equity, had a public float of less than $75 million as of a date within 30 days of the date of the filing of the registration statement, computed by multiplying the aggregate worldwide number of such shares held by non-affiliates before the registration plus, in the case of a Securities Act registration statement, the number of such shares included in the registration statement by the estimated public offering price of the shares; or in the case of an issuer whose public float as calculated under paragraph (1) or (2) of this definition was zero, had annual revenues of less than $50 million during the most recently completed fiscal year for which audited financial statements are available.” Whether or not an issuer is a smaller reporting company is determined on an annual basis.

Nov 30 is the last business day of PTSC's most recently completed second fiscal quarter. However, on Nov 15, the effective date of the new rule, we were still an accelerated filer. I will call the SEC tomorrow and find out if we have to wait three years based on PTSC changing its filing status after May 31, 2011.