From: Pam McArthur [Pmcarthu@MSRS.ORG]
Sent: Tuesday, November 25, 2003 5:13 PM
To: rule-comments@sec.gov
Subject: S7-19-03 Comments

VIA EMAIL
HARD COPY TO FOLLOW



						November 25, 2003



Jonathan G. Katz
Secretary
U.S. Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C.  20549-0609

	Re:	File No. S7-19-03 Corporate Board Nomination Reforms

Dear Mr. Katz:

	As Executive Director of the Maine State Retirement System, as a 
representative of the over 165,000 members and retirees who are the 
beneficial owners of the System's investments, and as an individual 
owning securities in my own right, I am writing to protest the inadequacy 
of the above-referenced proposed SEC rule.  The SEC's stated goal for the 
rule is to provide shareholders with less onerous and more effective ways 
to nominate corporate directors.  The goal is excellent, in fact, essential.  
The rule as proposed barely moves toward that goal.

	A share-ownership requirement, perhaps with a required holding period, 
should be the only hurdle to the ability of shareholders to put a director 
or directors on the ballot.

	The Commission must reconsider its thinking and proposal on this issue, 
and more quickly toward its own goal.

						Yours truly,



						Kay R.H. Evans
						Executive Director

KRHE/nlp
cc:   David S. Wakelin, Chair, Board of Trustees
         Members, Board of Trustees