Subject: File No. S7-16-07
From: Lance Wilcox, Ph.D
Affiliation: Professor of English

September 25, 2007

I am writing to express my hope that the SEC will not take any action resulting in the restriction of the power of corporate shareholders to file non-binding resolutions.

One of the strengths of capitalism is that, while keeping ownership of the means of production in private hands, it brings its own democratic processes into play by permitting private stockholders to file such resolutions and letting other stockholders vote on these resolutions as they see fit. I exercise this right frequently, both directly, by voting the proxies I receive from corporations in which I own stock, and indirectly, through the proxy voting of mutual funds I have money in.

It is difficult enough for private stockholders to make much headway in resolutions already due to the various ways that the voting process is stacked in favor of management. Managers always get the last word on shareholder resolutions, and the lazy man's option of casting one vote to accord with all the management preferences would not be tolerated in any other voting situation. It would be a terrible blow to stack the deck further by making it more difficult for private shareholders to file resolutions at all.

Please act to preserve the right of shareholders to file non-binding resolutions, and thus preserve one crucial field for democratic involvement in the economic sphere.

Lance Wilcox, Ph.D.