Subject: File No. 4-502
From: James McRitchie, Publisher
Affiliation: Corporate Governance

May 22, 2005

Mr. Jonathan G. Katz, Secretary
U.S. Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, DC 20549

Re: File 4-502

Dear Mr. Katz:

I write this as a shareowner and as the publisher of CorpGov.Net, an Internet site that has facilitated the ability of institutional and individual shareowners to better govern corporations, enhancing both corporate accountability and the creation of wealth since 1995. The current arbitration process is stacked against shareowners. The reforms requested in Les Greenberg's petition would go a long way towards creating balance. I urge you to enact them.

Additionally, any rulemaking in this area should include a requirement that arbitrators state the method and rationale behind behind their decisions. We deserve to know and requiring transparency would allow better monitoring of the process.

James McRitchie, Publisher
Corporate Governance
http://corpgov.net/news/news.html
9295 Yorkship Court
Elk Grove, CA 95758
916.869.2402