Subject: File No. S7-10-09
From: David L Turney

December 23, 2009

I strongly encourage the SEC to NOT adopt these proposed new "Proxy Access" rules this will only serve to facilitate narrow self-interest actions by the elite few that qualify for such direct access. This will further burden listed companies with new procedures having no possibility of material positive returns and will be of especially negative consequences for smaller listed companies. Already certain investors are attempting to intimidate listed companies into taking actions not in the best interests of the shareholder population as a whole this will just add one more avenue to such and will bring added pressure for short-term actions that would enhance selected shareholders at the expense of the larger shareholder population