I can has CS3 now (that CS4's been announced)?

(sorry for the cross-posting of this into different groups)

Does anyone have (or know of) any ROI studies on upgrading an enterprise from CS2 to CS3? (yes, I said to CS3)

Long story short, I half-jokingly asked our IT staff about upgrading to CS3 in time for the CS4 release. Their answer was, "sure, if you pay for it - for your department, and every other department that touches your stuff."

We just got upgraded to CS2 last year, after much cajoling ("you mean you're not using it? we thought you were, since everyone else here is...").

I've made all the usual arguments, about all the things CS3 fixes that we're working around now (e.g. separate opacity and blending for stroke, fill and content - woo hoo!), and about how virtually every how-to site has instructions for CS3 (they used to say, "oh, you can't do that in CS2," but now they don't bother), and how just about every plug-in and script that would take the tedium out of my job is written for CS3. But in the end, it comes to the bottom line. Someone needs a reason they need to spend money.

for full disclosure - and lest it sound like I'm whining - it was formerly my job to certify and deploy new software. I was the one who issued a resounding "No!" to a group of 6-8 people (out of 300) who wanted an upgrade to Photoshop 7 because of the new drop shadow filter. I told them how I used to have to make my own drop shadows, in v.2.0, before there were layers, using just the channels (as I waved my cane and told them all to get off my lawn) so I had little sympathy, and didn't see one filter justifying the cost.

So, yes, I really feel moving to CS3 would help me and my staff get a lot more work done faster and easier.

So, how do I convince someone it's worth the cost? I imagine that (in the last 3 years) since CS3's been out, someone's already done the heavy lifting and has numbers to back up my otherwise anecdotal info.