From: ftownsen@endpointgroup.com
Sent: Tuesday, November 18, 2003 6:10 PM
To: rule-comments@sec.gov
Subject: File No. S7-19-03


I, a director of Maxim Pharmaceuticals, Inc., a publicly traded company, 
oppose proposal S7-19-03 because the recent governnance reforms initiated by 
the stock exchanges and the SEC will make boards more independent and 
accountable.  The SEC should allow time for those reforms to work before 
imposing additional, unproven requirements on issuers.

I share the concerns and endorse the opinions expressed in the comment letter 
submitted by the American Socieity of Corporate Secretaries.

F. Duwaine Townsen
EndPoint Late-Stage Funds
8880 Rio San Diego Drive
Suite 500
San Diego, CA 92108
ftownsen@endpointgroup.com