Concord, CA 94518
January 19, 2018
Via email firstname.lastname@example.org
U.S. Securities and Exchange Commission
Office of Chief Counsel
Division of Corporation Finance
100 F Street, NE
Washington, DC 20549-2736
Re: Shareholder Proposal for Inclusion in Twitter, Inc. 2018 Proxy Statement
Ladies and Gentlemen:
Although Twitter’s January 18, 2018 letter to the SEC is well written, its conclusion to omit my proposal is not convincing.
The letter cited my similar proposals to other companies, such as to Goldman Sachs and Apple in 2014. I submitted these “one-size-fits-all” public policy proposals based on my knowledge and experience from China, Japan and the US (that is the reason I founded US-Japan-China Comparative Policy Research Institute), as I have witnessed many companies (such as Yahoo) have failed similarly in public policy. Twitter’s social media business is much more connected directly to public life than Goldman Sachs and Apple, as indicated also in the letter. In the case of Apple, although Apple claimed in the no-action request letter of October 31, 2014 that “The Company Has Substantially Implemented the Proposal”, it has not. The SEC did not concur with Apple when Apple tried to exclude my similar proposal to its 2018 shareholders meeting on December 21, 2017 http://cpri.tripod.com/cpr2018/SEC-Apple.pdf . Twitter’s business is very similar to facebook, which included my International Public Policy Committee proposal (#12) in its 2016 shareholders meeting. Why not learn from the leader of social media business?
Should you have any questions, please contact me at email@example.com or 925-643-****.
Cc: Sean J. Edgett