EXHIBIT 99

                    REPRESENTATION OF ARTHUR ANDERSEN LLP


March 26, 2002


Securities and Exchange Commission
450 Fifth Street, NW Judiciary Plaza
Washington, DC 20549

Re: CONFIRMATION OF ARTHUR ANDERSEN REPRESENTATIONS


This letter confirms that Arthur Andersen LLP, our independent public
accountants, have represented to us in writing that their audit was
subject to their quality control system for the United States accounting
and auditing practice to provide reasonable assurance that their
engagement was conducted in compliance with professional standards, that
there was appropriate continuity of Arthur Andersen personnel working on
the audit and availability of national office consultation, and that
availability of personnel at foreign affiliates of Arthur Andersen is not
relevant to this audit.

Very truly yours,


/s/
Ben Farahi
Chief Financial Officer






















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