Fulcrum Global Partners LLC Adopts the "Merrill Lynch Principles"

October 7, 2002

Fulcrum Global Partners LLC has fully adopted the "Merrill Lynch Principles" as follows.

Fulcrum Global Partners LLC:

• Has no link between compensation for analysts and investment banking;

• Prohibits investment banking input into analysts' compensation;

• Has created a review committee to approve all research recommendations;

• Has established a monitoring process to ensure compliance with the terms of the agreement between Merrill Lynch & Co., Inc. and New York State Attorney General Eliot Spitzer dated May 21, 2002 (" the Merrill Lynch Principles");

• Requires that upon discontinuation of research coverage of a company, we will disclose the termination and the rationale for such termination;

• Disclose in research reports whether we have received or are entitled to receive any compensation from a covered company for the past 12 months.

Please direct all inquiries to Robert Hoehn, Director of Research.

Sincerely,
Harry Needleman
Chief Operating Officer