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30 LARGEST STOCKHOLDERS-Continued

30 LARGEST STOCKHOLDERS As or FEBRUARY 7, 1972 Holder Number of

Number of shares Holder

shares Loeb Rhoades & Co., 44 Wall St., New York, N.Y--- 218,992 Pitt & Co., Bankers Trust Co., New York, N.Y. 5, 281, 301 Brown Bros. Harriman & Co., 59 Wall St., New York,

Kane & Co., Chase Manhattan Bank, N.A., New York,
N.Y..

200,004
N.Y.

2, 661, 000 Hare & Co., care of Bank of New York, 48 Wall St.,

Cudd & Co., Chase Manhattan Bank, N.A., New York,
New York, N.Y.

196,070
N.Y.

2, 607, 491 Dean & Davis, care of Wilmington Trust Co., Wilming

Cede & Co., Stock Clearing Corp., New York, N.Y.... 2,348, 306 ton, Del... 189,080 Mobil Oil Corp., New York, N.Y

1, 480, 077 F. J. Haffner & Co., Box 6147, Cleveland, Ohio.

185,904 Carson & Co., Morgan Guaranty Trust Company of New Kane & Co., care of Chase Manhattan Bank, Box 1508,

York, New York, N.Y...

1, 183, 497 New York, N.Y..

166,113 Nabank & Co., National Bank of Tulsa, Tulsa, Okla., 1, 034, 098 Leta M. Chapman, Box 3209, Tulsa, Okla..

159, 600 Trussai : Co., National Bank of Detroit, Detroit, Mich. 914, 465

Pace & Co., Mellon National Bank & Trust Co., PittsTotal.. 15,617,239 burgh, Pa--

877, 544 Sigler & Co., Manufacturers Hanover Trust Co., New York, N.Y.

827, 311 Brad & Co., First National City Bank, New York, N. Y.

798, 683 GULF OIL CORPORATION

Northern Natural Gas Co., care of J. C. Plourde, 2223
Dodge St., Omaha, Nebr...

733, 000 May 17, 1972.

Kelly & Co., Morgan Guaranty Trust Company of New
York, New York, N.Y.

673, 399 DEAR SENATOR METCALF: This will acknowledge re- Anderson & Co., the Fidelity Bank, Philadelphia, Pa... 662, 259 ceipt of your letter of May 2, 1972 addressed to Mr. E. D. Reing & Co., Morgan Guaranty Trust Company of New Brockett requesting information about our company's

York, New York, N.Y..

633, 606 shareholders. For your information, Mr. Brockett retired

Cross & Co., First Pennsylvania Banking & Trust Co.,
Philadelphia, Pa...

625,312 as Chairman of the Board and Chief Executive Officer on Steere & Co., Girard Trust Bank, Philadelphia, Pa. 619, 487 December 31, 1971. Mr. B. R. Dorsey, our President, was Batrus & Co., Bankers Trust Co., New York, N.Y.

520,592 designated Chief Executive Officer upon Mr. Brockett's

Emp & Co., Harris Trust & Savings Bank, Chicago, Ill-- 507,525 retirement.

Atwell & Co., United

States Trust Company of New
York, New York, N.Y..-

473, 189 With respect to your inquiry as to the total number of

Shaw & Co., Morgan Guaranty Trust Company of New voting shares of common stock, please be advised that as York, New York, N.Y.

464,044 of March 3, 1972, the Corporation had outstanding King & Co., First National City Bank, New York, N. Y.- 434,624 207,693,074 shares of its capital stock entitled to be voted

Dean & Davis, Wilmington Trust Co., Wilmington, Del. 433, 400

Saxon & Co., Provident National Bank, Philadelphia, at our Annual Meeting of Shareholders.

Pa..

424,763 We regret that we will be unable to comply with your The Sealy

& Smith Foundation for the John Sealy Hospirequest for a list of the 30 top shareholders in the company

tal, 200 University Blvd., Galveston, Tex..

400,000 and the amount of stock held by each. It is our practice The Equitable Life Insurance Society of the United

Jenkins & Co., Chemical Bank, New York, N.Y.

393,591 of long standing not to disclose specific information con

States, 1285 Avenue of the Americas, New York, N.Y. 377, 100 cerning individual shareholders. We consider our share- Barnett & Co., Bankers Trust Co., New York, N.Y. 372, 720 holders' names and holdings to be privileged information Heil & Co., United States Trust Company of New York, to be divulged only in accordance with applicable provi- Perc & Co., Northwestern National Bank of Minneapolis,

New York, N.Y...

359, 859 sions of the law.

Minneapolis, Minn..

344,300 Sincerely yours,

RUSSELL G. CONNOLLY,
Vice President and Secretary.

PHILLIPS PETROLEUM COMPANY

May 12, 1972.

DEAR SENATOR METCALF: This is in answer to your MOBIL OIL CORPORATION

letter of May 2, 1972, addressed to Mr. W. W. Keeler, 1972.

Chairman of the Board of Directors, in which you request DEAR SENATOR METCALF: In response to your letter of

certain information regarding our Company's common stock and

its stockholders. March 11, 1972 addressed to Rawleigh Warner, Jr., Chief

As of December 31, 1971, the Company had issued Executive Officer, Mobil Oil Corporation, I'm pleased to 76,192,076 shares, there were 1,451,401 of such shares held enclose a list of the 30 largest stockholders of Mobil Oil in our treasury and there were 74,740,675 shares outstandCorporation. This is the list as of February 7, 1972, the ing and entitled to vote. This information appears on page most recent date for which that information is now avail

19 of the enclosed annual report of the Company for 1971.' able. The first name listed in each case is the record owner.

You also requested a list of the 30 top stockholders of

our Company. We consider information with respect to In those cases where the record owner is known to us to be

our stockholders' names and the amounts of their holdings a "nominee", we have also listed immediately under the to be privileged and confidential information to be given record owner's name the name of the principal or fiduciary. only upon indication of proper purpose in accordance with

In response to the other question in your letter, the applicable provisions of the law. Since no such indication number of voting securities of the Corporation outstanding your request. However, on page 10 of the annual report

is evident from your letter, we must respectfully decline was 101,567,404 shares as of February 11, 1972, all of

some generalized statements about our stockholders one class and each having one vote.

appear. Very truly yours,

Sincerely,

HARVEY W. THOMPSON,
GEORGE A. BIRRELL,

Secretary.
General Counsel and Secretary. *Retained in committee fles.

MARCH 17,

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SHELL OIL COMPANY

proper and sufficient business reasons to effect rapidly and MAY 17, 1972.

accurately the transfer of stock entrusted to the care of

banking institutions there is nothing sinister about them. DEAR MR. METCALF: This is with reference to your Our Company is a Delaware corporation whose law letter of May 2, 1972, to Mr. Denis B. Kemball-Cook re

provides for disclosure of stockholder accounts only to questing information concerning certain shareholders and

stockholders upon a showing of a proper purpose. Absent the total number of shares of Common Stock of this Com

such a showing it is the Company's policy to keep such pany outstanding. For your information, Mr. Denis B.

matters confidential. Kemball-Cook retired from the Company on June 30, Sincerely yours, 1971. Mr. H. Bridges is now the President and the Com

H. L. SEVERANCE, pany's Chief Executive Officer.

Secretary. The Company is authorized by its Certificate of Incorporation to issue 80,000,000 shares of its Common Stock,

STANDARD OIL COMPANY (INDIANA) of which, as of May 10, 1972, there were outstanding 67,396,938 shares. Each share of Common Stock is entitled

May 9, 1972. to one vote for all purposes. On that date, Shell Petroleum DEAR SENATOR METCALF: This is in response to your N. V., The Hague, the Netherlands, beneficially owned letter of May 2 requesting a list of the 30 top stockholders 46,889,888 shares of Common Stock or 69.57 percent of the

in Standard Oil Company, the amount of stock owned by Common Stock outstanding: All of the voting shares of each, and the total number of voting shares of common Shell Petroleum N. V., a Netherlands company, are owned stock. 60 percent by Royal Dutch Petroleum Company, a Neth- We believe that the information regarding stock ownererlands company, and 40 percent by The Shell” Trans- ship which you request is a private matter between the port and Trading Company, Limited, an English company.

company and its shareholders. We feel that we should not The remaining shares of Common Stock of the Company voluntarily supply this confidential information to a third are held by approximately 33,330 shareholders. The foregoing is a matter of public disclosure. However, party, and hence cannot comply with your request.

As of April 30, 1972, there were 69,831,613 shares of since the Company is under a fiduciary obligation to the

common stock of Standard issued and outstanding. shareholders not to violate the confidentiality of their

Yours truly, respective holdings, other than as required by law, we

John E. SWEARINGEN, must respectfully decline to furnish any further informa

Chairman of the Board. tion in this regard. Sincerely, W. W. WESTERFIELD, Jr.,

STANDARD OIL COMPANY, INCORPORATED IN NEW Secretary.

JERSEY

MARCH 30, 1972. STANDARD OIL COMPANY OF CALIFORNIA

DEAR SENATOR METCALF: In replying to your letter of

March 11, I must tell you that it has been the long standMAY 8, 1972.

ing practice of our management not to disclose holdings of DEAR SENATOR METCALF: This is a reply to your letter individual shareholders to persons outside the Company, of May 2, 1972, to Mr. H. J. Haynes, requesting informa- for reasons which I hope you will understand. We regard tion on our stockholders and enclosing your April 25 the relationship between the Company and the shareremarks in the Senate.

holder as a private one, somewhat like that between a Our Company has issued 84,837,251 shares of common bank and its depositors and, in the absence of some legal stock.

requirement, would not wish to be guilty of disclosing a Our largest stockholder of record is Yerba & Co.--a shareholder's private affairs for the purposes of third nominee of the Crocker National Bank in San Francisco. parties. Normally, of course, third party inquiries arise Currently Yerba is the record holder of 4,784,000 shares- out of marital difficulties, creditors' claims, or just plain 5.6 percent of outstanding stock. This is held on behalf of curiosity of say a relative or a newspaper columnist. I approximately 21,400 employee members of the Com- fully appreciate that your inquiry must have a substantial pany's Stock Plan. These employee members have what is purpose in the public interest. Unfortunately, we have known as “pass through” rights to vote the stock in their been unable to establish any satisfactory dividing line accounts. Under this arrangement the bank Trustee sends between "good" inquiries and bad” inquiries and this has the Company's annual report and proxy solicitation

forced us to decline to make any voluntary disclosure. material to each member together with a voting instruc

I can tell you that the 30 largest shareholders of this tion form to be returned to the Trustee from the member.

corporation all happen to be intermediary holders, for the These instructions are confidential and the Company has

most part the nominees of banks who, as you know, hold no access to them. If instructions are not received from a

in their custody shares for a variety of investors--indimember, the stock in his trust account is sterilized". viduals

, estates, mutual funds, etc. --and for purposes of Bank officers authorized to sign in behalf of Yerba & Co.

convenience frequently lump such holdings into one or attend the Company's Annual Meeting of Stockholders

more nominee accounts. Thus, the nominee account has and cast votes according to the instructions they have

title to, but not beneficial ownership of, the shares and the received from the members.

real owners are not disclosed to the Company. I am giving you the above information on our largest

Our largest shareholder account happens to be the stockholder because it is a matter of public record as the

Trustee of our Thrift Fund, holding shares beneficially Company files a Registration Statement S-8 with the

owned by many thousands of employees of this Company Securities and Exchange Commission on this Stock Plan.

and its affiliates. This account currently holds 6.3 million I am also giving this detailed information to help explain nominee' accounts. Nominees have been created for Now Exxon Corporation.

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shares or something less than 3 percent of the 224,227,367 voting stock is shown, where the holders of approximately shares outstanding as of December 31, 1971. The range 34.7 percent of the voting stock are named, and where the among the 30 largest shareholders is from this largest holdings of its directors are listed. account down to a nominee which holds slightly over one- In view of the considerations of confidentiality, I trust half million shares, or less than two-tenths of 1 percent. this information will serve as an adequate substitute for To reiterate, there is no account among the 30 largest, that requested. with the exception of the Trustee, which appears to us to Very truly yours, be anything other than an intermediary nominee holder

H. ROBERT SHARBAUGH, for a bank or broker.

President. I regret that the problems touched upon prevent me from giving you all of the exact information you requested. I trust that the information which I have provided will be

TEXACO, INC. of use to you. Sincerely yours,

MARCH 28, 1972. M. M. BRISCO,

DEAR SENATOR METCALF: This refers to your letter of President.

March 11, 1972 addressed to Mr. Augustus C. Long in

which you request certain information regarding our THE STANDARD OIL COMPANY OF OHIO (SOHIO) Company's stockholders. For your_information, Mr.

Augustus C. Long is no longer Chief Executive Officer of

May 16, 1972. our Company. He retired as such on December 31, 1971 DEAR SENATOR METCALF: I have read with a great deal and is now Chairman of the Executive Committee of the of interest the copy of the Con,ressional Record which was Board of Directors; Mr. Maurice F. Granville is Chairenclosed with your letter of May 2, 1972. I do not believe man of the Board of Directors and Chief Executive that information about our company's stockholders is the Officer. kind of information that would be helpful to you. I am We must advise that we consider our stockholders' enclosing a copy of a proxy statement which describes

names and stockholdings to be privileged and confidential in detail the transaction whereby The British Petroleum information to be divulged only upon a showing of proper Company Limited acquired the equivalent of a 25 percent purpose in accordance with applicable provisions of the common stock interest in our company.' Pages 2 and 3 law. No such purpose is indicated by your letter, and we of the proxy statement describe this interest and the

must therefore respectfully decline your request. table on Page 3 shows that British Petroleum can even

In case it may be of assistance to you, we can advise tually own 54 percent of our common stock.

that as of February 1, 1972, our Company had outstandWith respect to disclosure of information about stock. ing 274,285,268 shares of common stock, which shares holders, I can understand that companies may have

were held by 299,021 owners of record. No one stockholder differing policies. For example, it is interesting to note

owned as much as 1.5 percent of the outstanding shares. that on those lists which were supplied to you there are

Very sincerely yours, no named individuals. Like several of the companies

WILFORD R. YOUNG, mentioned in the Congressional Record it is our policy

Senior Vice President and General Counsel. not to disclose information about stockholders which is not otherwise publicly disclosed unless we are legally required to do so. Sincerely,

UNION OIL COMPANY OF CALIFORNIA
Alton W. WHITEHOUSE, Jr.,
President.

JUNE 7, 1972.

DEAR SENATOR METCALF: I regret that my absence SUN OIL COMPANY

from the country has delayed my reply to your letter of

MAY 8, 1972. May 2. MY DEAR SENATOR METCALF: This will acknowledge As at December 31, 1971 the Company had 28,371,285 receipt of your letter of May 2, 1972 requesting a list of Common_Shares (excluding Treasury Shares) and 9,the 30 top stockholders in the Sun Oil Company, the 627,954 Preferred Shares outstanding. Each Common amount of common stock each holds, and the total number Share and each Preferred Share is entitled to one vote. of voting shares of common stock.

You have also requested that we give you a list of the It is not the practice of this Company to disclose any thirty top stockholders and the amount of Common Stock information pertaining to stockholders, which may be of a confidential nature. We are willing, however, to supply treat our stockholders' names and stock holdings as

each holds. It has always been our practice to regard and you with any information previously made public. To

confidential for reasons that I am sure you will appreciate. this end, I am enclosing a copy of our Company's most I believe also that this is in accordance with the laws of recent proxy statement, which was circulated to our shareholders to give them notice of the Company's the circumstances we must respectfully decline to give you

this Company's state of incorporation-California. Under Annual Meeting of April 18, 1972.' I specifically call your the names and stock holdings you request

in
your

letter. attention to pages (1) and (2), where the total outstanding

Very truly yours, *Retained in committee files.

FRED L. HARI

EY, President.

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29-553 0.74 - 17

200

B. Other Industrial Companies

We wish to cooperate with you and your Committee in

any way we can to develop information which we are free ALLIED CHEMICAL CORPORATION

to give you. We believe we have the responsibility, how

ever, in the absence of being served with legal process, to

JUNE 2, 1972.
DEAR SENATOR METCALF: Your letter of May 2, 1972, holders.

hold in confidence the specific holdings of our stockrelating to stock records of this Corporation, has been referred to me for reply.

In order to be as helpful as possible, while still observ

ing our responsibilities, we attach a list of our thirty The only voting securities of Allied Chemical Corpora- largest stockholdings, identified only by kind of stocktion are shares of Common Stock. As of April 30, 1972, holder, together with the amount of the holding. there were 27,558,773 shares of Common Stock out- We do have some data that will indicate the number of standing.

actual beneficial holdings standing behind each record Your request for a list of the “30 top stockholders' holding, and our estimate appears as a number in parenand "the amount of common stock each holds" calls for thesis next to each account. This number is derived from confidential information which is to be disclosed only to the number of sets of proxy soliciting material requested the extent that disclosure is duly authorized. One of the by the nominal holder at the time of the mailing with restrictions with respect_to such information is the pro- respect to our last annual meeting. vision in the New York Business Corporation Law to the

Sincerely yours, effect that persons seeking to inspect stockholder records

David A. De Wahl, are to show a purpose which is in the interests of the

Vice President, General Counsel and Secretary. business of the corporation. No such showing has been made by your letter. Accordingly, we respectfully decline

Approximate to comply with your request.

Number of number of underThank you for your interest in Allied Chemical Rank in size of holdings,

shares (88 of lying beneficial Corporation.

kind of stockholder

Mar. 31, 1972)

holdings Sincerely yours, BRIAN D. FORROW, 1. Insurance company

654, 000

Unknown Vice President and General Counsel.

24. Insurance company

66, 100

Unknown 2. Bank.

545, 098 3. Bank..

464, 990

38 6. Bank.

201, 292

260 14. Bank..

154, 400

Unknown AMERICAN HOME PRODUCTS CORPORATION

17. Bank.

110, 975

125 19. Bank.

93, 985

14 May 24, 1972. 20. Bank.

84, 650

35 23. Bank.

66, 643

28 DEAR SENATOR METCALF: This is in reply to your letter 28. Bank..

62, 160

Unknown dated May 2, 1972 addressed to Mr. William F. Laporte, 4. Brokerage firm.

370, 437

3,300 Chairman and President of American Home Products 5. Brokerage firm.

240, 977

683

13. Brokerage firm.. Corporation. Your letter arrived while Mr. Laporte was

214

156, 113 18. Brokerage firm.

99, 100

699 overseas and has been referred to me for reply.

25. Brokerage firm.

64, 266

590 At the present time we are uncertain as to the propriety 29. Brokerage firm.

60, 599

475 of sending the names of the 30 largest record holders of

30. Brokerage firm.

59, 316

500

Individuals. our shares. We do regard our shareholder lists as being is. Individuals.

167, 580

161, 975 confidential and feel that we would be obligated to 12. Individuals..

156, 425 obtain the consent of any shareholders whose names

16. Individuals.

113, 380

21. Individuals. appear on the list. We are quite certain that no individual

71, 276

26. Individuals. shareholder owns as much as 1 percent of our outstanding 27. Individuals.-

63, 462

63, 100 shares. Record holders representing trusts and pension 7. Miscellaneous

193, 630

Unknown funds very likely would hold substantially more if all of 8. Miscellaneous.

179, 000

Unknown

10. Miscellaneous. their holdings were consolidated.

162, 984

Unknown 15. Miscellaneous.

126, 200

Unknown At December 31, 1971, American Home Products 22. Miscellaneous.

69, 250

Unknown Corporation had 51,679,000 common shares outstanding and 902,390 convertible preferred shares outstanding.

ARMCO STEEL CORPORATION We enclose a copy of our 1971 Annual Report which provides further data concerning our shares and capital

May 22, 1972. structure.' Please see pages 18 through 24.

DEAR SENATOR METCALF: Your letter of May 2 has Very truly yours,

been referred to me for reply. We thank you for the copy R. P. GREENLAW, of your comments contained in the Congressional Record Vice President and Treasurer.

of April 25, 1972.

On February 25, 1972, Armco Steel Corporation had outstanding and entitled to vote 29,411,991 shares of

common stock and 4,050,858 shares of preferred stock, all AMERICAN-STANDARD

of which are entitled to one vote per share. May 15, 1972.

I regret that with respect to your request for the names DEAR SENATOR METCALF: This is in reply to your letter

of the thirty top stockholders in our Company and the of May 2, 1972, addressed to William D. Eberle, who is

amount of common stock held by each, we are unable to no longer associated with this company.

comply. We consider the names of our stockholders and

the number of shares held by each to be confidential in*Retained in committee Ales.

formation which we, on our part, will not disclose. Under

the laws of Ohio, Armco's state of incorporation, even a Consequently, it does not seem to us that this inforstockholder is not permitted to inspect our shareholder mation will be helpful in determining whether there is records unless he states his purpose therefor and such concentration of stock ownership and control of large purpose is deemed reasonable and proper.

corporations. Consequently I hope you will understand the position Sincerely, we must take on your request and the reason for it.

CHARLES F. DONNELLY,
Very truly yours,

Senior Executive Vice President.
WILLIAM R. BAILEY,
Vice President and General Counsel.

LARGEST 30 RECORD HOLDERS OF COMMON STOCK AS OF
APRIL 30, 1972

Number of
Holder

shares BENDIX CORPORATION Stuart & Co.

1, 207, 680 Cede & Co.

609, 528 May 22, 1972. Barnett & Co...

400, 400

Brown Bros. Harriman & Co. DEAR SENATOR METCALF: In response to your letter Firjer & Co..

253, 460

195, 000 of May 2, we are enclosing the list you requested which Geary & Co...

181, 585 shows the 30 largest shareholders of record holding Trude & Co.

169, 700 Common Stock of Bendix and the number of shares held

Kabo &

160, 000

Edal & Co. by each as of April 30, 1972. As of that date, the total

138, 700 Gerlach & Co.

137, 532 number of outstanding shares of Common Stock eligible Ince & Co...

122, 646 to vote was 12,321,609 shares.

Searsfund & Co..

89, 400 It should be emphasized that this list is not indicative

Elm & Co.

87, 060 Steere & Co.

84, 877 of either concentration of ownership of Bendix stock or of Merrill Lynch, Pierce, Fenner & Smith..

80, 591 concentration of voting control. Nearly all of the share- Cust & Co...

59, 888 holders listed are either banks or major brokerage houses

Map & Co...

57, 687 or their nominees who are generally not the beneficial

Dade & Co.

51, 784

O'Neill & Co.. owners of the shares held of record by them. Consequently, Luff & Co.

50, 000

50, 000 such stockholders do not have the ability to exercise Surtic & Co...

48, 890 control over the corporation since, in genera), they do not Charles Stewart Mott Foundation.

47, 188 have discretionary authority to vote the shares held in

Cudd & Co.

46, 203 their names on any matter for which stockholder approval Royork & Co

Cross & Co.

42, 211 is at all in doubt.

40, 445 Maslif One & Co.

40, 000 For instance, Stuart & Co., the largest stockholder

Main & Co.

40, 000

Hax & Co. of record, is the nominee for the Trustee of the Corpora

40, 000 Costo & Co.

40, 000 tion's Salaried Employees' Savings & Stock Ownership Hoos & Co..

39, 300 Plan. All participants in this plan are solicited for voting instructions prior to each Shareholders' Meeting. Likewise, although in certain instances banks may have

BETHLEHEM STEEL CORPORATION specific discretionary authority to vote stock held by them as fiduciaries, we understand that it is the policy of

May 18, 1972. most major banks to solicit voting instructions from the beneficial owners of stock held in agency, custodial and

DEAR SENATOR METCALF: Mr. Cort has asked me to investment management capacities and to vote the stock reply to your letter of May 2, 1972, requesting “a list of in accordance with such instructions, even where the

the 30 top stockholders” of Bethlehem, “the amount of banks are not specifically required to solicit instructions ing shares of common stock” of Bethlehem.

common stock each holds," and "the total number of votunder the terms of the governing instruments.

To answer your last question first, on February 29, 1972, Cede & Co., the second largest stockholder of record, is the record date for Bethlehem's 1972 Annual Meeting of a depository for certificates of stock traded on the New Stockholders, there were outstanding in the hands of the York Stock Exchange recently formed to facilitate the public 44,482,938 shares of its Common Stock, each entimely settlement of transactions without the need for

titled to one vote per share. In addition, 1,504,180 shares the physical exchange of certificates. Cede & Co. is bound by the rules of the New York Stock Exchange in voting to vote.

were held in Bethlehem's treasury, which are not entitled shares held of record by it.

I regret that I cannot furnish you the names of the Under these rules stock held of record, for the benefit of 30 top stockholders of Bethlehem, because we regard inothers, by members of the Exchange (or their nominees) formation on individual stockholdings as confidential and cannot be voted unless the member firms have transmitted believe that we have a fiduciary responsibility to our proxy soliciting material to the beneficial owners. Such stockholders to protect the confidentiality of their holdings. member firms must vote such stock in accordance with However, in order to cooperate with you as much as I any voting instructions received from the beneficial feel that we properly may, I have prepared and enclose owners. Member firms may vote such stock in their herewith a list of the 30 largest stockholdings of record on discretion only if, after soliciting proxies, (1) no voting February 29, 1972, which, although it does not identify instructions have been received, (2) they do not have the individual stockholders, describes the nature of each knowledge of any contest as to the action to be taken and holder, as, for example, "broker,” “nominee for mutual (3) the matter to be voted on will not affect substantially fund,” “nominee for bank fiduciary accounts,” etc. I trust the rights or privileges of such stock.

that the list will be satisfactory for your purposes.

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