Subject: S7-16-07

August 14, 2007

Dear Chairman Cox,

I want to express my opposition to any attempt to weaken shareholders' right to file non-binding advisory resolutions under Rule 14a-8.

As a longtime institutional investor since 1955, I have observed that shareholder proposals have provided an important voice in the governance of corporations. To eliminate these proposals would severely curtail shareholder democracy. This right is an important tool of management accountability to shareholders.

I urge you to enhance the dialogue between corporations and their owners on strategic matters.

Sincerely yours,

Robert J.Kiernan