Subject: File No. 4-670
From: William Michael Cunningham

December 3, 2013

We note the Securities and Exchange Commission is holding a "roundtable on the use of proxy advisory firm services by institutional investors and investment advisers.

The roundtable..will be divided into two sessions. In the first session, participants will discuss, among other topics, the current use of proxy advisory services, including the factors that may have contributed to their use, the purposes and effects of using the services, and competition in the marketplace for such services.  In the second session, participants will discuss, among other topics, issues identified in the Commission’s 2010 concept release on the U.S.
proxy voting system, including potential conflicts of interest that may exist for proxy advisory firms and users of their services, and the transparency and accuracy of recommendations by proxy advisory firms."

We renew our earlier criticisms concerning the lack of true diversity at this and other SEC-sponsored Roundtables and refer the Commission to our earlier comments on this topic:

Thank you.
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Creative Investment Research, Inc.