From: Kristin Gilbertson [kgilbertson@stanford.edu]
Sent: Wednesday, December 03, 2003 4:44 PM
To: 'rule-comments@sec.gov'
Subject: S7-19-03: 

I am writing in support of the proposed rule (S7-19-03) to provide for 
security holder director nominations.  I presently manage the Stanford 
University endowment's $4 billion equity portfolio.

The rule provides institutional and other strategic shareholders with 
a powerful tool to ensure management accountability.  The two triggers 
(35% withhold vote and shareholders majority at the annual meeting) 
provide clear and actionable standards for implementation while protecting 
the broad shareholder base from nuisance and/or special interest nominations.  
Extension of the security holder proposal privilege to a "group" ensures 
equal rights for even the small stakeholder and is consistent with 
democratic principles.

The specific triggers were an essential element in my having comfort 
with the proposed rule; however, they are discussed only on page 11 of 
the release.  My one suggestion would be to clearly specify the triggers 
in the summary to allow for others to more easily review the document.

 

Kristin Gilbertson

_______________________________

Kristin Gilbertson

Managing Director, Public Equities

Stanford Management Company

2770 Sand Hill Road

Menlo Park, CA 94025

Ph. 650-926-0240

Fax 650-854-9257

kgilbertson@stanford.edu