From: Nancy Davlantes
Sent: September 25, 2007
To: rule-comments@sec.gov
Subject: File No. S7-16-07


Dear Chairman Cox:

Please add my name to those asking the SEC to preserve the nonbinding shareholder proposal. Shareholder proposals have helped to promote transparency, improve corporate governance and performance, and raise important issues ranging from greenhouse gas emissions to sweatshops to sustainability reporting. In this way, investors have also brought visibility to important business risks that can have a profound impact on the value of our investments.

I am concerned thatshareholders' rights to propose advisory resolutions under Rule 14a-8 may be curtailed or eliminated. These resolutions as a valuable tool for shareholders to make their voices heard about the direction of our companies. I specifically oppose granting companies the ability to "opt out" of the shareholder resolution process, substituting electronic petitions or chat rooms for resolutions, or increasing the percentage vote required for resubmission in subsequent years.

Many of the most critical corporate reforms of recent years have been promoted by these small individual and institutional investors. The current proxy rules have facilitated a rich and diverse dialogue on some of the most critical issues of our time, from climate change to excessive executive compensation. Please keep these current rules in place.

Recent corporate scandals have served to underline the importance of more communication, more transparency, and more accountability - not less. Nonbinding shareholder resolutions have proven effective in holding companies accountable to their owners. I ask that the Commission safeguard, not undermine, their use.

Thank you for considering my comments..

Yours sincerely,

Nancy Davlantes