Subject: File No. S7-33-10

December 17, 2010

Should the proposed rules be modified to limit the fees awarded for whistleblowers legal expenses, it would make sense in these days where legal process is as much a battle of wallets to pay for legal costs as a battle of information and ideas, to have balancing limits on the other side. Perhaps awards for whistleblower legal expenses (reguardless of actual expenses) or the reward for whistleblowing should be adjusted upwards by the the defense legal expenses when the defense loses.

Michael McMullen, P. E.