February 2, 1998 Securities and Exchange Commission 450 Fifth Street NW Washington, DC 20549 Re: Release Nos. 33-7475, 34-3932l; File No. S7-27-97 As former Corporate Secretary of Litton Industries, Inc. and Western Atlas Inc. and now Corporate Secretary of UNOVA, Inc., I am pleased that the SEC is dealing with the subject of "householding." While we support the SEC's concepts, the SEC is urged to expand its proposal to include provisions which will allow issuers to realize cost savings in the mailing of annual reports and proxy statements to their registered holders as well as to their beneficial holders. As indicated in the publication The Shareholder Service Optimizer, "... when it [the SEC release] gets to the subject of Annual Report mailings, the newly proposed rules, while helpful, fall far short of what can be accomplished." Both Litton Industries and Western Atlas mail their proxy statements along with their annual reports. It is anticipated that UNOVA will follow this practice as well. Since the SEC's proposal is limited to annual reports, the proposal will not allow these companies to recognize savings in their mailings to registered holders. On the other hand, the New York Stock Exchange's recent householding rule permits its member firms to household both annual reports and proxy statements for street name shareholders. As the Optimizer also points out, "The release seems to forget that with respect to annual meeting materials, shareholders still need to receive individual proxies. They might come as part of a single mailing - if the mailer's technology permits multiple proxies to be inserted in a single envelope per household, but, nonetheless, each voter and each position has to be identified individually." The Commission is urged to reconsider and expand its householding proposal in order to provide companies with a means of recognizing savings and reducing waste. Sincerely, Virginia S. Young Vice President and Corporate Secretary