Subject: Protect shareholder rights (File No. S7-16-07)(naf)(sn# 255)

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

September 25, 2007

Chairman Christopher Cox

I am concerned about proposed initiatives that would curtail or eliminate the right of investors to file shareholder resolutions. I believe that investors have an important role to play in ensuring that our corporations are run properly, whether through restraining management excesses or by provoking changes within the company.

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 also called attention to practices that can impact the financial security of companies and ultimately their success and return for investors. Through shareholder resolutions investors are rightly able to register their concern that excessive executive compensation that can harm profitability, reputation and staff morale. Equally investors may sometimes need to impress upon management the need to tackle societal and environmental problems their business may contribute to. For example, companies that recklessly pollute or brands that rely on sweatshop labor may be at risk for lawsuits, consumer boycotts or damaging public protests. Investors, who after all have a financial stake in these companies, need to be able to protect their investment by steering companies away from practices that carry such financial risks.

While management may not always welcome shareholder resolutions I feel that they can be a useful 'reality check' for companies who may be missing a potential liability or an opportunity. When shareholders express concern about a companies contribution to global warming they may be helping that company find energy efficiency savings or prepare it for a future in which greenhouse gas emission may be more tightly regulated and traded.

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.

Sincerely,
Justin Grindley