Subject: File No. 4-537: Shareholder Resolutions

July 23, 2007

Dear Chairman Cox:

As a concerned investor, I was alarmed to learn that the SEC is considering a proposal to restrict or eliminate one of the most important tools that shareholders like myself can use to make our concerns known to corporate management. I urge you to drop the suggested proposal curtailing investors' right to file advisory resolutions under Rule 14a-8.

In a democracy, no organization should be exempt from overview by its members nor from democratic control. Shareholder resolutions are an essential expression of the democratic process, and restricting or eliminating them would be essentially anti-democratic.

Please let me know what action you intend to take on this issue.

Yours sincerely,

David Merkowitz