1. Please describe what, if any, decision-useful information would be lost if certain recognized intangible assets (for example, non-compete agreements or certain customer-related intangible assets, or other items) were subsumed into goodwill and amortized. Please be as specific as possible. For example, include specific analyses you perform that no longer would be possible.
2. How reliable is the measurement of certain recognized intangible assets (for example, non-compete agreement or certain customer-related intangible assets)?
3. To gauge the market activity, are you aware of instances in which any recognized intangible assets are sold outside a business acquisition? If so, how often does this occur? Please explain.
4. Of the possible approaches presented, which would you support on a cost-benefit basis? Please rank the approaches (1 representing your most preferable approach) and explain why you may not have selected certain approaches.

a. Approach 1: Extend the private company alternative to subsume certain CRIs and all NCAs into Goodwill.

b. Approach 2: Apply a Principles-Based criterion for intangible assets

c. Approach 3: Subsume all intangible assets into goodwill

d. Approach 4: Do not amend the existing guidance.

5 as it relates to approach 2 (a principles-based criterion) please comment on the operability of recognizing intangible assets based, in part, on assessing whether they meet the asset definition.

6 Approaches 1-3 assume that subsuming additional items into goodwill would necessitate the amortization of goodwill. Do you agree or disagree? Please explain why.