Subject: Comment on File Number 4-637

February 4, 2013

Dear Members of the Securities and Exchange Commission:

In 2010 Target Stores, which enjoyed broad support in the LGBT community, tried to surreptitiously contribute to Tom Emmer's gubernatorial campaign in Minnesota. Tom Emmer had taken rabidly anti-gay positions. The contribution was made from treasury funds without consent or even notice to shareholders and Directors. The contribution was engineered by their CEO who sent his daughter to a school that barred gays from attendance.

As happens, the contribution came to the light of day. The ensuing boycott of Target knocked tens of millions (if not hundreds of millions) off Target's market value.

This decision on the use of corporate funds was highly relevant to shareholders of Target. Corporate political contributions are, by nature, highly controversial and can have major effects on shareholder values. Clearly, shareholders have a right to advance notice.

Thank you for considering my comment.


Nicholas Lefevre