Subject: Please protect 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

Dear Chairman Cox:

Please protect the right of investors to file shareholder resolutions. I strongly urge you to take *no* action on the proposed initiatives that would curtail or eliminate this essential right. This is such an un-American idea thatit is absurd that this is even an issue in America.

Shareholder resolutions are an indispensable 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, improve corporate governance and performance, and keep the unscrupulous from achieving unethical ends. They have called attention to numerous 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. In America, we do business above the board, or the law levies consquences. Those who are promoting this unethical change are interesting only in dodging our laws. Do not let this criminal element prevail!

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

Thank you for your attention to my comments.

Sincerely,
James Cunningham