Jan. 31, 2020
Comment on File Number File No. S7-23-19 To: Vanessa A. Countryman, Secretary, Securities and Exchange Commission From: John Chevedden Date: January 31, 2020 Re: Comment on File Number File No. S7-23-19 In regard to the 38 votes between 40% and 50% that were achieved in 2019 by 4 shareholders: Many shareholders do not have access to independent proxy voting advice and management almost universally opposes these proposals. A number of companies have a large block of insider shares which almost universally opposes these proposals. A number of companies oppose these proposal with false or misleading opposition statements. A number of companies have the bad manners of introducing these proposal with a negative introduction and follow the proposal with a more elaborate negative statement. A number of companies have the bad manners of inserting a negative image next to the shareholder proposal. A number of companies have the bad manners of implying that the proponent is a dead beat on the ballot and some shareholders use the only ballot description to decide. Pus some companies use shareholder money to advertise against shareholders proposals. Thus a number of the 38 votes between 40% and 50% in 2019 would have been majority votes if there was a level playing field.