Subject: Comment on File Number 4-637

February 1, 2013

Dear Members of the Securities and Exchange Commission:

I don't think corporations are people, nor do I think money is speech. The majority of Supreem Court justices apparently disagrees with me, and has ruled that corporations have as much right to influence elections as voting citzens have. In practice, the extent of that influence is proportional to money spent, rather than, say, to the strength of the ideas, and many corporations are able to exploit financial resources well in excess of those available to ordinary voters. Although they can't vote, corporations can therefore disproportionately affect the outcome of an election.

At present, however, corporations are not even obligated to acknowledge their involvement, much less the nature and extent of that involvement, despite the fact that, if they are publicly-traded corporations, shareholders--as owners--have the right to know how corporation resources are spent. So I strongly support the SEC issuing a rule that requires publicly-traded corporations to disclose all spending on political activities. Such disclosure should be public, because we are all either current or potential shareholders, and therfore deserve access to complete details of all corporate spending. In particular, we have a right to discover the amount a corporate spending on politics (both directly and through intermediaries), and which candidates or issues are being promoted or attacked.

Thank you for considering my comment.


Philip Rubin