Subject: File No. S7-42-10
From: Dan Mikell

February 15, 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:

Strong guidelines for beneficial business rules help businesses to maintain honorable practice in countries where good business is not firmly supported. When business are pressured to do business with and to comply with people who make poor choices, they may rely on the laws of their homeland to resist and counter corporate cultures and powerful individuals who may not be otherwise guided or constrained to make the best decisions for all concerned.

Dan Mikell