UNITED STATES SECURITIES AND EXCHANGE COMMISSION

STATION PLACE 10OF STREET, NE

WASHINGTON, DC 20549-2736 Office of FOIA Services

January 31, 2013

Mr. Gregory Troy 3023 Ash Court Mason, OH 45040 RE: Freedom of Information Act (FOIA), 5 U.S.C. 552 Request No. 13-02166-FOIA

Dear Mr. Troy: This letter responds to your request, dated November 26, 2012, and received in this office on December 4, 2012, for "all records regarding the investigation of Getty Images by the SEC for the backdating of stock options which took place around 2006". We have identified information concerning Getty Images that may be responsive to your request. Under the FOIA, you are considered an "all others" requester. As such, you are required to pay search fees (beyond the first two hours which are free), and duplication fees (beyond the first 100 pages which are free), in accordance with our fee schedule. The estimated cost to search the records (four boxes) under the FOIA is $840.00. This estimate does not include the cost of copying any releasable records at $.24 per page. Since the records are voluminous, if requested, we would process them on our first-in, first-out [FIFO] track. This procedure is consistent with the principles set forth in Open America v. Watergate Special Prosecution Force, 547 F.2d 605 (D.C. Cir. 1976). At present we anticipate that it may take eighteen to twenty-four months before we can begin to process your request. Investigatory records generally consist of transcripts of testimony, exhibits, and miscellaneous evidentiary materials. Therefore, you may want to consider narrowing the scope of your request.

Mr. Greg Troy January 31, 2013 Page Two

13-02166-FOIA

If you are interested in having us place your request in our First-in First-out Track, please write or call me by February 11, 2013, and identify the records of interest to you and your commitment to pay the search and duplication fees. Note, you will be charged fees even if the data located is subsequently determined to be exempt under the FOIA. If you have any questions, please contact me at osbornes@sec.gov or (202)551-8371. You may also contact me at foiapa@sec.gov or (202) 551-7900. Sincerely,

Sonja Osborne FOIA Lead Research Specialist