Subject: Comment on File Number 4-637

March 21, 2012

I am writing to urge the Securities and Exchange Commission to issue a rule requiring publicly traded corporations to publicly and promptly disclose, in detail, all of their spending that is intended to influence (1) the outcome of elections or (2) the actions of legislators or other public officials, including all spending related to lobbying, and to disclose, in detail, the particular actions of each legislator or other public official that that the spending is intended to influence and in what direction it is intended to influence those actions, and whether and how each of those expenditures will thereby serve the interests of stockholders and whether and how it might affect the interests of the public.

I ask that these public disclosures be in as much detail as possible, with particular emphasis on all of the ways in which the expenditures and the consequent actions of lobbiests might be effective in influencing the actions of legislators and other public officials, and detailing anything of value, including payment of a more-than-equal share of joint expenses, that has been given to each legislator or public official, and when and where. The detail should be sufficient to allow the SEC, other government agencies, and the public to determine whether the expenditures have been in full compliance with all relevant laws.

Thank you for considering my comment.

Richard Montague

Longmont, CO