Comment letter
analysis is appropriate as it has been theorised (Sutton 1984), and supported by
Georgiou’s (2002) survey of U.K. companies, that the use of other lobbying methods
is significantly associated with making comment letter submissions. Further, Georgiou
(2002) found that corporations that do not make comment letter submissions are
unlikely to lobby through other methods. Therefore, comment letter content analysis
facilitates the identification of the positions of the majority of lobbyists and enables
empirical investigation of how the IASB develops standards in the presence of
lobbyin