November 22, 2019
File Number S7-23-19 From: olmsted <olmsted7p@earthlink.net> Sent: Friday, November 22, 2019 11:37 PM To: ShareholderProposals <shareholderproposals@SEC.GOV> Subject: File Number S7-23-19 Ladies and Gentlemen, Please extend the comment for Rule 14a-8 rulemaking to at least 120 days. The September 6, 2019 announcement of the Staff that it will change its long-standing practice and sometimes decline to respond favorably or unfavorably to no-action requests may have a significant impact on the number of proposals appearing on proxy statements. There has been no projection on whether the impact of this dramatic and vague change will favor proponents or management or be neutral. So far it seems to favor the big law firms that will have greater visibility on Staff outcomes as result of having a large number of client experiences with the Staff that they can record in their exclusive database. John Chevedden