From: Haig Hovaness [hovaness@pipeline.com] Sent: Sunday, October 13, 2002 1:34 PM To: rule-comments@sec.gov Subject: Petition for Rulemaking (SEC File No. 4-461) Hon Mr. Pitt, I urge you to act swiftly to empower direct election of board members by shareholders by requiring companies to bear the cost of proxy solicitation for such votes. If the shareholders are the owners of a corporation, why should they not be able to put directors of their own choosing on the board? Such a measure would go a long way toward addressing many of causes of poor corporate governance. SEC Rule 14a-(8)(i)(8) specifically allows public corporations to exclude director nominations from shareholders. This rule should be rescinded as soon as possible in the name of responsible corporate reform. The eyes of the American investment community are upon you; please act in our interests. Yours truly, Haig Hovaness Pelham Manor, New York