Subject: File No.
From: Paul A Legnetti, Mr.
Affiliation: Vice President Chief Technical Officer at Breen Color Concentrates

March 21, 2017

I support modifying or repealing this rule in order to ease the reporting burden on US manufacturing companies. We are a private company and therefore not subject to the SEC Conflict Minerals rule however we are required to report because our customers require it if we are to remain their supplier. We know from our supplier that the tin present in some of our products does not originate from ores mined in the defined conflict regions and have documentation to support it. Yet, every year we must spend dozens of hours completing the reporting templates for our customers. The rule is confusing because, as it is written, it applies to any of the substances noted in item A whether they originate in Wyoming or a conflict state.

"As defined in 2010 United States legislation, Dodd-Frank Wall Street Reform and Consumer Protection Act, Section 1502(e)(4):
CONFLICT MINERAL.—The term conflict mineral means—
(A) columbite-tantalite (coltan), cassiterite, gold, wolframite, or their derivatives or
(B) any other mineral or its derivatives determined by the Secretary of State to be financing conflict in the Democratic Republic of the Congo or an adjoining country. (available at"

Paul Legnetti