Subject: proposed file # S7-22-19 Amendments to Exemptions from the proxy rules for proxy voting advice
From: James Elbaor

Feb. 26, 2020


As an American who has served in the military and active investor for many many years, I am very disappointed to see the above will amendment and our family is strongly against the amendment for numerous reasons as we feel this is an end run to diminish  shareholder rights which is negative for shareholders and negative for American values and America's future. 

It will be a negative for investors and make it difficult for independent proxy advisors to remain impartial and independent, and promote freely disseminated information, and comprehensive  research  that is unbiased by a corporation or other. 
It is a boldface plan to give more power to the corporations to be able to exert substantial control and bias against independent opinions which is un-American, and I suspect unconstitutional. It will allow  wealthy powerful corporations to become a censor over the free flow of information. 
This will cripple what our Founding Fathers felt was so precious, that is, the free flow of independent ideas and information, "a free press." 

This proposed rule would establish a controlled dissemination of information subject to pressure by corporations to change independent ideas and strongly control and inhibit free flow of information.  Even worse, such a rule could increase the threat of expensive litigation on independent opinions inhibiting free flow of information. 

Thus, we are very strongly against the implementation of this proposed rule. 

If you have any questions, please not hesitate to contact me. Please confirm receipt. 

Thank you 

James  Elbaor MD 
American Institute of Orthopaedics & Sports Medicine