Subject: File No. 4-637
From: Jeff LaMarca
Affiliation: Marcellus Capital Management, LLC

March 21, 2013

Dear Ms Murphy and Commissioners,

I am writing to urge you to implement rules requiring the disclosure of all spending and donations by publicly traded companies involving any type of political activity. These rules should cover any type of support for any organization that advocates for public policy or supports public officials in any capacity, including industry trade groups, nonprofits, unions, think tanks, and chambers of commerce.

As an owner of a business, I believe that I have a right to at least know when the managers of my business, whose salaries I pay, are using my money to influence public policy or elections. These types of expenditures are not related to the operations of the business, so there is no justification for nondisclosure based on competitive advantages. I believe it is the duty of the Securities and Exchange Commission to protect my rights as a shareholder.

Thank you,

Jeff LaMarca
Marcellus Capital Management, LLC