“…Written submissions to the rule-makers are one way in which lobbying takes place. The analysis of comment letters to accounting standard-setting bodies is the most frequently used approach to examine attempts to influence the standard-setting process (e.g., Allini, Aria, Macchioni, and Zagaria 2018;Bline and Skekel 1991;Durocher and Fortin 2011;Durocher, Fortin, and Cote 2007;Georgiou 2002Georgiou , 2010Holder, Karim, Lin, and Woods 2013;Kidwell and Lowensohn 2018;Saemann 1999;Schalow 1995;Tandy and Wilburn 1996;Yen, Hirst, and Hopkins 2007). Sutton (1984) reasons that the cost/benefit calculation prompts the decision to lobby rule-makers.…”