Subject: File No. 4-637

February 2, 2013

Dear Members of the Securities and Exchange Commission:

Secret political spending by corporations is fraud.

Read the word and dig its full meaning: fraud.

Period.

I am an investor and an attorney. I am politically active, as a voter, and donor (my mere thousands may not matter in the grand scheme, but it's a lot to me). Corporate spending on politics is a material factor a significant number of investors do consider.

So I strongly support the SEC issuing a rule in the near future that would require publicly traded corporations to publicly disclose all their spending on political activities.

Both shareholders and the public deserve to know how much a given corporation spends on politics (directly and through intermediaries), and which candidates are being promoted or attacked.

Thank you for considering my comment.

Sincerely,

Mark Palermo