Subject: Comment on File Number 4-637

February 7, 2013

Dear Members of the Securities and Exchange Commission:

Shareholders should have the right to know whether the companies they own are making political contributions, how much money is being spent, what issues and positions are being supported, whether these expenditures put the company at risk, whether they are in line with the company's ethical values and standards of business conduct, what intermediaries and agents are being used for the contributions, and, most importantly, how these expenditures benefit the company's business strategy and serve shareholder interests.

A company's board of directors is responsible for ensuring that all these questions are being addressed before political contributions are made. Shareholders must know the answers in order to fulfill their role of monitoring the performance of portfolio companies and holding their boards accounbtable.

Thank you for considering my comment.


John Wilcox