Subject: S7-06-22 comment
From: Stuart Heinrich
Affiliation:

Jun. 25, 2023

As explained by White & Case law, this proposal would not consider a participants net exposure. Thus it would allow fully hedged participants through out and call options that have no net positive exposure to a company to obtain any arbitrary amount of voting power, despite not owning any real shares or even carrying any net exposure to the company. This would effectively legalize operational ballot stuffing and would enable the predatory manipulation of shareholder voting resolutions. Such a rule is preposterously fraudulent and absolutely should not pass.