Subject: File No. S7-40-10
From: William Leight

February 3, 2012

Generic SEC comment file

Dear Generic SEC comment file,

I am disappointed to learn that the final rule for Section 1502 of the Dodd-Frank Act, dealing with conflict minerals, has been delayed once again. I urge you to release a strong, final rule as soon as possible that gives life to the intent behind the statute. Given the urgency of the humanitarian situation in eastern Congo and the key role of the minerals trade in fueling conflict and human rights abuses, such a rule should reject any delays in implementation. Additionally, the rule should adopt the OECD due diligence standard, which represents an international consensus approach to the conflict minerals trade, ensure that all conflict minerals have equal reporting standards, and include all companies, regardless of size. Furthermore, the rule should apply to all companies that use minerals in their products, regardless of the percentage -- Congress explicitly decided against including a de minimus rule in the legislation -- and issuers should be required to take sufficient steps to accurately determine whether its conflict materials originate in the DRC (the reasonable country of origin standard). Finally, reports should be filed with the Commission, not just furnished. Thank you for your attention to this important matter.


William Leight