Subject: Protecting shareholder rights (File No. S7-16-07)

Chairman Christopher Cox
Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549-1090

September 25, 2007

Chairman Christopher Cox

Now, a corporation is a peculiar legal construct: an entity created for the sole purpose of generating profit.

While a person may have a diversity of goals -- a desire to do good, a need for security, a desire for natural beauty and so forth -- the corporation is rather divorced from more enlightened pursuits in the interest of producing revenue. This often leads to actions that, while they may be in the immediate self-interest of the corporation, are often at odds with the good of society (or indeed the planet) as a whole.

In short, corporations don't have an organ of conscience. They have the profit devil sitting on one shoulder, but lack the conscience angel sitting on the other shoulder. Hence corporate actions are often unbalanced.

One of the correcting, ameloriating influences helping corporations take into account broader considerations is the right of investors to file shareholder resolutions.

So rather than reducing the restraining hand of conscience on corporations by curtailing or eliminate the rights of shareholders, it makes sense for the good of society to retain or strengthen these rights.

Shareholder resolutions are an invaluable tool for investors who want to make their voices heard with regard to the direction of their companies. Shareholder resolutions have helped to promote transparency and improve corporate governance and performance. They have called attention to critical issues, including global warming, nuclear power, sweatshops, executive compensation, natural resource extraction, and other major societal and environmental problems that, when not addressed, often end up costing shareholders and their companies as a result of lawsuits, damaged reputations, consumer boycotts, public protests, and low staff morale.

The many corporate scandals of recent years highlight how important it is to have more, not less, corporate transparency and accountability. Shareholder resolutions have proven effective in holding companies accountable to their owners. I ask that the commission safeguard, not undermine, their use.

Thank you for your attention to my comments.

Frank Glass