Chairman Christopher Cox
Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549-1090
September 30, 2007
Dear Chairman Cox:
I urge you to protect the right of investors to file shareholder resolutions and to take no action on the proposed initiatives that would curtail or eliminate this essential right. It is particularly ironic that such proposals would occur in a democratic country.
To deny the right of shareholders to speak, under the guise of government regulation, essentially infringes on their First Amendment rights. At present, shareholders have the right to "speak" in this manner. It is only government regulations which would deprive them of this right. Therefore, it is government action in violation of the FIrst Amendment.
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.