Subject: File No. S7-18-09
From: Leighton W Strader
Affiliation: Partner, Virginia Ventures, LLC

August 30, 2009

We're not a TPM, but have been in the investment management business for
30 years. This seems like a good court challenge. If what you're
telling me is that a TPM, who makes His or Her living in a honest manner
by "speaking"
to prospective public clients on behalf of a potential investment
manager, when the TPM does not contribute to that public entity, then I
think we have an obstruction of the ability of that TPM to make a
living. How is it a lobbyist or other procurement contractors can speak
with public officials on behalf of Halliburton, Northrop Grumman, IBM or
other providers and not investment-related solicitors?

I know you're not the jury here, but just trying to understand the logic
before I launch an air raid on Chris Dodd, Mary Shapiro and others.

Leighton Strader