Subject: File No. S7-10-09
From: Wilhelm DeBrunhilde, III
Affiliation: Retired Engineer

August 22, 2010

I do not believe in the silly US proxy access ideas. I believe the US stockholders should vote, but not nominate unless they control the company already. We may now perhaps to begin new idea:

I see there are very many other ways to influence a company. As example, look at the HP and what the once sexy actress did to the CEO that we know about, but not by making this proxy access go for it. It is silly, as are American's who think they are promoting good practice with all of this sillyness.

I propose instead that a company's directors be replaced if they company does not pay at least 10% of EBT in Stock Dividends to the stockholders. 10% is not high, but enough for me to be happy.

I also propose a form of "no cookie access" that all directors and officers take, meaning a vow of chastity when they sign on, but with meaningful compensation, pension, and option claw backs for any violation. Board would review all violations. This idea would surely stop the types of cookie access problems I keep reading about in the news papers. Had your US companies done so, I would not need to read about HP, Boeing IBM and many other top executives getting caught with their fingers, hands or worse in these unvelcome cookie jars. This type of access we as stockholders do not need. Run the business, I say, not the sex shows. Of this you can be sure, silly proxy access would not cure this problem, but "no cookie access" would quickly cure this problem.

These ideas will keep US stockholders happy, the equity prices rising, and at the same time avoid this sillyness you American's keep preaching with this so-called proxy access. Please now to have proposal written as I say.