Subject: S7-31-22: WebForm Comments from Garrett godfrey
From: Garrett godfrey
Affiliation: CEO of 805 Group Inc.

Feb. 24, 2023



February 24, 2023

 Dear Securities and Exchange Commission,

I am writing to express my strong support for Rule 34-96495, which proposes amendments to the rules governing shareholder proposals in order to improve the efficiency and effectiveness of the shareholder proposal process.

The proposed amendments would update the eligibility and resubmission requirements for shareholder proposals, while still allowing shareholders to have a meaningful voice in corporate decision-making. The amendments would also promote engagement between companies and their shareholders, which would improve corporate governance and accountability.

I believe that these proposed amendments strike the right balance between preserving the ability of shareholders to submit proposals and ensuring that the process is efficient and effective. By updating the eligibility and resubmission requirements, the amendments would help to prevent the submission of proposals that are unlikely to receive significant support and reduce the burden on companies in addressing them.

Furthermore, the proposal to increase the ownership threshold for submitting proposals would encourage shareholders to take a more significant stake in a company before making proposals, which would incentivize them to become more informed and engaged in the company's affairs.

Overall, I strongly support Rule 34-96495 and urge the SEC to adopt these proposed amendments to the rules governing shareholder proposals. These updates would improve the efficiency and effectiveness of the shareholder proposal process, promote engagement between companies and their shareholders, and enhance corporate governance and accountability.

Thank you for considering my comments.

Sincerely,
Garrett Godfrey