Subject: File No. S7-14-10
From: Scott A. Scherff
Affiliation: The Timken Company

October 14, 2010

I am the Corporate Secretary of The Timken Company, a global manufacturer of bearings and highly engineered alloy steel. We are a publicly-held company traded on the New York Stock Exchange.

We would like to take this opportunity to comment on a couple of specific aspects of the SEC's concept release on the U.S. proxy system.

First, with respect to Section III of the release concerning fees, competition and choice related to direct communication with shareholders, we believe in free market competition. A competitive environment should be established to allow issuers to choose service providers on the basis of price and quality of service. The current system severely limits competition and the potential benefits of competition, including increased innovation and improved service.

Second, the recent regulatory changes to the shareholder environment increase the importance of direct communication with shareholders. The NOBO/OBO classification system prevents public companies from knowing many of its shareholders. This outdated system should be eliminated, allowing transparency of share ownership and direct communications between issuers and their investors.


Scott A. Scherff