U.S. Securities and Exchange Commission

Litigation Release No. 18387 / October 2, 2003

Accounting and Auditing Enforcement Release No. 1886 / October 2, 2003

SEC v. Sidney V. Corder, Randal J. Sage and Brian J. Yates, Civil Action No.
1 03-CV-1436-JDT-TAB (S.D. IN)(filed October 1, 2003)

SEC Sues Three Former Officers of Analytical Surveys, Inc. for Financial
Fraud

   On October 1, 2003, the U.S. Securities and Exchange Commission (SEC)
   filed a complaint in the United States District Court for the Southern
   District of Indiana against Sidney V. Corder, age 61, of Zionsville,
   Indiana, Randal J. Sage, age 46, of Carmel, Indiana and Brian J.
   Yates, age 39, of Colorado Springs, Colorado, former officers of
   Analytical Surveys, Inc. (ASI), a Colorado corporation that provides
   computerized maps to customers under long-term contracts. During the
   relevant time period, Corder was ASI's President, Chairman and CEO,
   Sage was ASI's Chief Operations Officer, and Yates was ASI's
   Controller.

   According to the complaint, Corder, Sage, and Yates engaged in a
   fraudulent scheme that caused ASI's 1999 fiscal year revenue and net
   earnings to be materially inflated in press releases and periodic
   reports filed with the SEC through the use of several improper
   accounting methods. The SEC alleges that Sage caused ASI to improperly
   recognize revenue on long-term contracts by directing employees to (1)
   "finish contracts on indirect," where employees misallocated direct
   costs properly attributable to contracts to indirect, or overhead,
   accounts; (2) engage in "cost-shifting," where employees improperly
   shifted future direct costs from one contract to another, when the
   work performed related to the first contract and did not reflect
   progress on the second contract; and (3) improperly lower estimates of
   total direct costs on certain contracts or not increase cost estimates
   as necessary. All of these methods were impermissible under the
   percentage of completion method for recognizing revenue used by ASI.
   Generally accepted accounting principles (GAAP) require that, under
   the percentage of completion method, estimated contract costs be
   periodically reviewed and revised to reflect accurate information. The
   SEC further alleges that Corder (1) knew or was reckless in not
   knowing that Sage and other employees had engaged in these fraudulent
   accounting practices; and (2) directed employees to, among other
   things, finish contracts on indirect to avoid reducing revenue.
   Finally, the SEC alleges that Yates (1) also knew or was reckless in
   not knowing about this conduct described above; and (2) approved or
   acquiesced in finishing contracts on indirect, including Corder's