{"content":[{"text":"February 3, 2020","bbox":{"left":0.432827,"top":0.121949,"width":0.13427499999999998,"height":0.020212000000000008}},{"text":"Ms. Vanessa A. Countryman \n Secretary \n U.S. Securities and Exchange Commission \n 100 F Street NE \n Washington, DC 20549","bbox":{"left":0.117686,"top":0.191646,"width":0.33653,"height":0.08990899999999999}},{"text":"Re: Procedural Requirements and Resubmission Thresholds under Exchange Act \n Rule 14a-8 / 17 CFR Part 240; Release No. 34-87458; RIN 3235-AM49; File No. S7- \n 23-19 \n Dear Ms. Countryman:","bbox":{"left":0.117686,"top":0.30648,"width":0.7527320000000001,"height":0.08253800000000006}},{"text":"The Corporate Governance Coalition for Investor Value (the “Coalition”) was formed to \n provide a forum for the discussion of issues among its members to advocate for strong corporate \n governance policies, and federal securities laws that promote long-term value creation for \n investors. Coalition members represent American businesses of all sizes, from every industry \n sector, and geographic region. These businesses produce the goods and services that drive the \n American economy, employing and creating opportunities for millions of Americans, and \n serving the countless communities nationwide in which they operate.","bbox":{"left":0.117686,"top":0.406107,"width":0.7561700000000001,"height":0.122305}},{"text":"The Coalition appreciates the ongoing work by the Securities and Exchange Commission \n (“SEC” or “Commission”) to modernize the federal proxy rules. The Coalition and its members \n have long been concerned about the decline in the number of U.S. publicly-traded companies \n over the last twenty years, and we believe that a proxy system which has empowered a small \n group of activists over the vast majority of shareholders is a contributing factor to that decline. \n Accordingly, we support several aspects of the Commission’s November 5th rule proposal \n entitled “Procedural Requirements and Resubmission Thresholds under Exchange Act Rule 14a- \n 8” (“Proposal”).","bbox":{"left":0.117686,"top":0.543073,"width":0.75885,"height":0.14218200000000003}},{"text":"Discussion","bbox":{"left":0.117686,"top":0.700028,"width":0.08831400000000002,"height":0.02098500000000003}},{"text":"The Coalition and its members believe that effective communication and engagement \n between a company and its shareholders are critical to creating long-term value for shareholders. \n SEC rules governing shareholder proposals were adopted in order to facilitate the consideration \n of constructive ideas put forth by investors seeking to improve the governance of a company. \n The Coalition supports a regulatory framework that allows shareholders to make \n recommendations or suggestions that could improve a company’s performance and garner a \n significant level of shareholder support.","bbox":{"left":0.117686,"top":0.734588,"width":0.7586450000000001,"height":0.12479600000000002}}],"images_bbox":[],"images_bbox_not_text_overlap":[]}