Subject: File No. S7-42-10
From: Stephen Strathearn

February 12, 2012

Dear SEC Commissioners,

Please do not give in to industry pressures on Section 1504 of the Dodd-Frank Act (the Cardin-Lugar Amendment) - and make sure that ALL companies are covered, every country and every project gets reported, and loopholes that would allow large sums of money to go unreported are closed.

My Comment:

All US companies are required to follow SEC guidelines when dealing with foreign companies. They are probably the most stringent in the world. Overall, I think that it is a good thing that we have ethics. Corruption is no good for the common man. However, China and other countries operate by a different system and as you know their ethics are quite different than ours. So, they get an unfair advantage in 3rd world countries that we no longer have. However, I think we need to set an example so I do agree with the SEC. Although, I wouldn't doubt that our oil companies would like to return to business like it used to be.

Stephen Strathearn