December 29, 2005
December 29, 2005
Mr. Jonathan G. Katz
Secretary
Securities amp Exchange Commission
100 F Street NE
Washington DC 20549-9303
RE: Companies Use of Notice and Access Model to Furnish Proxy Materials
Dear Mr. Katz:
RadioShack Corporation is strongly in favor of the proposed Notice and Access model to furnish proxy materials to our stockholders for several reasons.
1. With approximately 60,000 registered and Street name stockholders, RadioShack incurs substantial cost every year to mail to its stockholders. Our companys financial resources would be better used driving value to these very same stockholders by investing in initiatives that produce financial returns rather than spending on regulatory ritual which adds no value.
2. The proposed rule reflects the reality of todays market place. Like many companies, our financial materials are already available in electronic form and it is standard practice for existing and prospective investors big and small domestic and foreign to access official company information electronically. Trends in electronic voting and traffic to our electronic materials are up suggesting that people embrace this way of doing business.
3. The Notice to stockholders would provide companies with a unique opportunity to include some language encouraging stockholders to read the materials and participate in the process. Since the proxy material packet would be reduced to a single letter or Notice, readers may be more likely to read, retain, and act on the information versus todays environment in which readers are inundated with a thick mailing. Important messages in todays proxy material environment are diluted by the clutter of the reports.
4. The Notice to stockholders could include an easy to remember shortcut or alias Internet address making it simpler for investors to access materials and vote. For example, the address to RadioShacks materials is: http://radioshackcorporation.com/ir/annuals.html. But we could create a link to that same page for investors as: radioshackstockholder.com.
5. The option of getting hard copy materials sent upon request is fair and easy. We believe this provides an added element of comfort for those investors requiring it.
Separately, we hope you will consider loosening the e-consent rule requiring stockholders to give prior consent for the electronic delivery of company materials. Should the Notice and Access model become formal regulation, clearly it would be an endorsement of conducting stockholder business electronically. Today, we have e-mail addresses of several stockholders, but we are unable to force e-consent on this group given todays rules. We hope you will consider rules allowing us to do this in the future.
Sincerely,
James M. Grant
Senior Director Investor Relations
RadioShack Corporation