file no. S7-19-03From: McCormick, Dale [Dale.McCormick@maine.gov] Sent: Thursday, November 06, 2003 3:12 PM To: rule-comments@sec.gov Subject: file no. S7-19-03 Mr. Jonathan G. Katz Secretary U.S. Securities and Exchange Commission 50 Fifth Street, N.W. Washington, D.C. 20549-0609 Dear Mr. Katz: I believe that the proposed rule on corporate boards of director nomination process is inadequate and should be substantially amended before it is adopted. I am the State Treasurer of Maine and a member of the Board of Trustees of the Maine State Retirement System. The thresholds that have been proposed are too high for the rule to have an impact. They require an expensive proxy fight to even get to the more reasonable step 2. Eliminate step 1 and just allow institutional investors who own 5% of the shares of a company to place a name on the annual slate for election to the Board of Directors. Thank you for your attention. Dale McCormick, State Treasurer of Maine