Jun. 26, 2023
To whom it may concern, proportional ownership of a publicly traded company is the sum of shares someone owns divided by shares outstanding. Adding beneficial ownership rights to derivatives artificially increases the denominator in the simple equation above and dilutes the proportional ownership all while violating the rights of the company itself because it didn’t issue more shares. A company alone has the sole right to issue shares. The Citizens United Supreme Court case established precedence that corporations can be afforded similar rights to a sovereign individual. By proposing beneficial ownership rights to derivatives the SEC is proposing violation to constitutional law. If a speculator wants the rights of ownership in a company let them go into the open market and purchase the security. Perhaps that way we can get true price discovery while preventing obvious conflicts of interest. That is why I reject the amendments to Rule 13d-3 to deem holders of certain cash-settled derivative securities as beneficial owners of the reference covered class. Moreover, I encourage the adoption of structured, machine-readable data language for filing Schedules 13D and 13G, as it ensures efficient and standardized reporting. Sincerely, Daniel Kulodzik BlueMail for Android herunterladen