From: Joyce Ludwig
Sent: September 25, 2007
To: rule-comments@sec.gov
Subject: File No. S7-16-07


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

Dear Chairman Cox:

It used to be that corporations were required to be good citizens and conduct honorable business, but that model has changed and not for the better. American Corporations reflect on this country when they conduct their business, so it is a matter beyond just so-called free trade. Unfortuneately, many reflect very badly on our country as well as themselves.

If shareholders choose to get a little less return or growth in exchange for better business conduct, then that should be something they can decide. I believe that shareholders often take a longer view than managers looking at the next quarter or two. So it is strange that shareholders wanting to build the business over the long term would lose that right to short term, scorched earth business practices.

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.

Please protect the right of investors to file shareholder resolutions and take no action on the proposed initiatives that would curtail or eliminate this essential right.

Thank you for your attention to my comments.

Sincerely,
Joyce Ludwig