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256,

In connection with the enclosed list, you should note

BOISE CASCADE CORPORATION that, while the aggregate holdings of our 30 largest stockholders of record amount to 10,811,882 shares, very few

MAY 18, 1972. of those shares are owned beneficially by the stockholders DEAR SENATOR METCALF: Mr. Hansberger has asked of record. For example, 3,849,105 shares, or 35 percent

me to reply to your letter of May 2 requesting information thereof, were held by the nominee for the Central Certifi- about Boise Cascade stockholders and common stock. I cate Service and a broker, substantially all of which repre- regret that we cannot provide all the information you are sent shares held by brokers but owned beneficially by tens seeking, but I am happy to supply an answer to one of of thousands of their customers, and 5,016,292 shares, or your two requests. 46 percent thereof, were held by 16 nominees for one or As of April 30, 1972, the total number of voting shares more mutual funds, the beneficial owners of which are the of Boise Cascade common stock was 31,110,038. hundreds of thousands of their stockholders.

You also requested a list of the 30 top stockholders of Very truly yours,

Boise Cascade. I am sorry that this information can't be ROBERT C. SONNEMAN,

supplied. We consider this information to be confidential, Secretary.

and would only reveal it to a Boise Cascade stockholder

upon establishment of a proper business purpose. 30 LARGEST RECORD STOCKHOLDERS As or FEBRUARY 29, 1972

Thank you for your interest in Boise Cascade Corpora

tion.
Number of

Sincerely,
Holder

shares Nominee for central certificate service.

3,205,708

ALICE E. HENNESSEY, Nominee for mutual fund..

1,100,000

Corporate Secretary. Nominee for various mutual funds..

751, 732 Broker...

643, 397 Nominee for mutual fund..

605,000 Nominee for various mutual funds..

525,579

BORDEN INC. Nominee for mutual fund..

340, 974 Bank fiduciary accounts.. 263, 241

MAY 10, 1972. Nominee for bank fiduciary accounts.

,086

DEAR SENATOR METCALF: Our Chief Executive Officer, Nominee for mutual fund.

250,000 Do...

250,000

Mr. Augustine Marusi, has asked me to reply to your Do.

245,000 letter dated May 2, 1972. (Please note that our current Foreign issuer of bearer deposit receipts.

199,690 address is 277 Park Avenue and the correct designation Nominee for bank fiduciary accounts.

183, 242

is Mr. Marusi.) Do...

176,500 Nominee for mutual fund..

160, 200 As the Proxy Statement for our most recent Annual Doc.

153, 177 Meeting states, there were 29,090,507 shares of common Custodian for foreign holders.

146,960 stock outstanding for Borden Inc. as of February 23, Nominee for bank fiduciary accounts.

140, 100

1972 and entitled to vote at that meeting. Testamentary trustees..

127,330 Nominee for mutual fund.

120,000

Your

request for the names and stock holdings of our Nominee for bank fiduciary accounts.

119,567 30 top. stockholders presents a problem, namely the legal State teachers pension fund..

118,600 impediment of confidentiality that involves the rights of Individual..

110,852

third parties including individuals. The transcript of your Nominee for various mutual funds.

110,000 Nominee for mutual fund..

105,000 April 25 remarks in the Senate, which you enclosed with Custodian for foreign holders.

104, 317 your letter, shows that several companies resolved this Nominee for various mutual funds.

problem by disclosing the names to you, although the Do...

102,000 Do

95,618

transcript does not show whether the identified parties

consented. An equal number of companies apparently Total..

10,811,882 felt constrained by the legal impediment.

The publication in the Congressional Record of the information disclosed to you compounds our problem.

We believe that we cannot condition our response upon BOEING COMPANY

confidentiality. Accordingly, we most respectfully are un

MAY 10, 1972. able to make this information available under these cirDEAR SENATOR METCALF: Reference is made to your cumstances. We hope you will understand that our willletter of May 2, 1972, requesting certain information about ingness to cooperate with you must be weighed against our stockholders. We believe it is not proper to voluntarily adherence to prescribed procedures under the laws of our furnish the names of our stockholders.

state of incorporation affecting the legal rights of others.

Very truly yours, Perhaps the following information, however, will sub

BERNARD NEMTzow, stantially meet your requirements:

Vice President, General Counsel and Secretary. We have outstanding 21,683,102 shares of stock.

The 30 largest stockholders of record hold in the aggregate 6,074,411 shares which represents 28.01 percent

BURLINGTON INDUSTRIES, INC. of the outstanding shares.

May 17, 1972. The 30 largest stockholders are comprised of 4 brokers, DEAR MR. METCALF: This is in response to your letter 25 nominees and 1 individual.

of May 2, 1972 to Mr. Myers requesting certain informaSincerely yours,

tion concerning the outstanding stock and stockholders of J. E. PRINCE, Secretary. this Company

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Ás of a recent date, there were outstanding 26,768,671 30 LARGEST HOLDERS OF COMMON Stock AS APRIL 30,1972—Con. shares of common stock of the Company of which 270,380

[In thousands and in descending order) shares were held in the treasury leaving a pet of 26,498,291

Number of shares outstanding in the hands of the public.

Holder

shares The largest stockholder of the Company is the Profit Merrill Lynch, Pierce, Fenner & Smith..

396

344 Sharing Plan of the Company which held, at a recent date,

Morgan Guaranty Trust... 2,722,086 shares or a little over 10 percent of the out

Affiliated Fund (Lord, Abbett & Co.).

300 standing stock. Such shares are held by Wachovia Bank & Abacus Fund....

44 Trust Company, N.A., as Trustee under the Plan, through

First National Bank of Denver...

305 its nominee Mark & Co. for the benefit of some 14,000 employee members of the Plan. The Trustee affords the

Hamilton Fund.

217 members of the Plan the opportunity to instruct the Founders Mutual.

88 Trustee how they desire to have the shares which are

Manufacturers Hanover Trust.

297 allocated to their account voted at the annual meeting;

Whitehall Foundation..-

267 in the absence of instructions the Trustee votes the shares in its discretion. The shares held by the Plan are being

(A_ nonprofit corporation established by former CPC

President George Moffett and funded primarily by regularly distributed to members of the Plan or their

his estate-among other activities, its trustees manbeneficiaries upon retirement, death or termination of age a college scholarship program for CPC employees employment.

and their children.) With the exception of a few individual stockholders, none Bankers Trust Company

218 of whom hold more than one-half of 1 percent of the out- Chase Manhattan Bank.

218 Swiss Credit Corp-.

211 standing stock, the next largest stockholders of record of

Plan B (Stock held for CPC employee thrift plan)

196 the Company among the top 30 are nominees, brokers or

Swiss Bank Corp...

193 others who generally are not, as you know, beneficial Chemical Bank.

177 owners of the securities held in their accounts but who

8 may hold for any number of trusts, estates, mutual funds,

Guardian Mutual (Cedar Street Consultants, Inc.)....
Other accounts...

169 insurance companies, individuals or others unknown to this Company. Only two of these hold more than 1,000,000 State of Texas public retirement system.-

175 shares, the largest holding less than 1,200,000 shares. Julius Garfield..

162

139 It is not our policy to release information concerning

American Bank & Trust Co., Pa... the individual stockholdings of our stockholders without

Penn Square Mutual Fund.

135 the consent of our stockholders. However, we trust that Other accounts. the foregoing general information, although not specifi

Girard Trust Bank..

134 cally in the form you requested, will be useful to you. Very truly yours,

First National Bank of Jersey City: Group Securities (U.S.
LEWIS E. BOROUGHS,
Life Mutual Funds Management)--

128 J. and R. Swanson.

120 Secretary and Associate General Counsel. Bank of New York.

107 U.S. Trust Co.--

102 First National City Bank.

101 CPC INTERNATIONAL INC. George Garfield..

100 S. B. Penick, Jr....

100 May 24, 1972. Loeb, Rhoades & Co....

89 DEAR SENATOR METCALF: We are pleased to respond to Union Bank of Switzerland.

87 your request of our Chairman, Howard C. Harder, for a Wilmington Trust Co.: Decatur Income Fund Inc. (Delalist of our 30 largest stockholders and the extent of their ware Management Co. Inc.).

85 holdings.

Brown Brothers, Harriman & Co....

79 The enclosed list, compiled as of April 30, 1972, indi

R. S. Swanson, Jr.

78 American National Bank & Trust Co..

77 cates not surprisingly that most of the largest holders are

Manufacturers National Bank (Detroit).

77 institutions which are nominees for undetermined but undoubtedly large numbers of beneficial owners. Where we are aware of it, we have shown the major accounts for whom these nominees hold stock. We do not know, how

CATERPILLAR TRACTOR CO. ever, which of these nominees seek the voting instructions of the beneficial owners, and which cast an "uninstructed”

May 17, 1972. vote.

DEAR SENATOR METCALF: This is in reply to your letter The number of our common voting shares outstanding is approximately 23,687,000 and the number of shareholders

of May 2, 1972, addressed to Mr. William Blackie. some 83,600.

Attached is a list of our top 30 shareholder accounts as Sincerely,

HOWARD F. HARRIS, of April 24. Where the account stands in the name of a Vice President, Public Affairs. nominee we have listed under the name of the registered

owner the name of its principal, with one possible excep30 LARGEST HOLDERS OF COMMON STOCK AS OF APRIL 30, 1972

tion. Judging from the name, Carson & Co. may be a (In thousands and in descending order)

nominee, but we cannot identify it as such.

Number of
Holder

shares

Our total number of voting shares of common stock National Bank of Detroit...

732 outstanding on April 24, 1972, was 56,916,130, all common

stock. Mutual Income Fund (Heritage Securities, Inc.)---- 30

Sincerely, Other accounts.

702

M. SARGENT, Secretary.

30 LARGEST ACCOUNTS AS OF APRIL 24, 1972

We much regret that under these circumstances we do (Caterpillar Tractor Co.)

not feel at liberty to comply with your request. However,

Number of information already in the public domain, through the Holder

Shares

medium of proxy materials and other filings with the Finat & Co., care of the First National Bank of Chicago. 2, 676, 779 Sigler & Co., care of Manufacturers Hanover Trust

Securities and Exchange Commission, reveals that TheoCompany, New York.

1, 273, 018

dore J. Munchak, Nathan I. Lipson and Dwight J. Stuart & Co., care of First National City Bank, New

Thomson are large shareholders. York...

1, 272, 937

Sincerely,
Atwell & Co., care of U.S. Trust Co. of New York. 859, 958

Karl R. BENDETSEN,
Pace & Co., care of Mellon National Bank & Trust Co.,
Pittsburgh.

771, 766

Chairman and Chief Erecutive Officer. Dean & Davis, care of Wilmington Trust Co.---- 744, 100 Cede & Co., care of Stock Clearing Corp

737, 309 King & Co., care of First National City Bank, New York.

707, 695 Trussal & Co., care of National Bank of Detroit.

597, 882 Cudd & Co. care of the Chase Manhattan Bank.

530, 283

CHRYSLER CORPORATION New York State Teachers Retirement System..

492, 700 Thomas & Co. care of First National City Bank, New

APRIL 5, 1972. York...

483, 300 Kane & Co. care of the Chase Manhattan Bank.

DEAR SENATOR METCALF: Per your request to our

481, 031 Gerlach & Co. care of National City Bank of New

President, Mr. John J. Riccardo, I enclose a list showing York..

406, 191 the thirty top stockholders of Chrysler Corporation as of Rucal & Co. care of the Bank of California, North

February 25, 1972, the record date for our Annual MeetAmerica.. How & Co., care of the Northern Trust Co.---.

404, 238 ing, and the number of shares of common stock each holds.

398952 Tnom & Co., care of St. Louis Union Trust Co.--

365, 476

As of that date, there were outstanding a total of 51,128,Cortact & Co., care of the Bank of California, North

876 shares of Chrysler Corporation common stock. America.

359, 901

Yours very truly, Carson & Co...

357, 963 Barnett & Co. care of Bankers Trust Co..

355, 500

PAUL A. HEINEN, Chetco, care of National Shawmut Bank of Boston... 355, 000

Associate General Counsel and Secretary. Shaw & Co., care of Morgan Guaranty Trust Company of New York.

331, 457 Bark & Co. care of State Street Bank & Trust Co.--- 320, 000

30 TOP STOCKHOLDERS AS OF FEBRUARY 25, 1972 Merrill Lynch, Pierce, Fenner & Smith, Inc.-

271, 008 Reing & Co., care of Morgan Guaranty Trust Company

Number of New York

Holder 263, 990

of shares Olen & Co. care of First National Bank of Chicago..

260, 551

Cede & Co., Box 20, Bowling Green Station, New York, Kelly & Co. care of Morgan Guaranty Trust Company

N.Y..

6, 179, 144 of New York..

256, 063

National Bank of Detroit (as trust exg. with Chrysler Calpers & Co. care of the Bank of California, North

Corp. dated May 18, 1956), Trust Department, P.O. America (Sacramento)250, 000 Box 222, Detroit, Mich.

5,044,884 Equitable Life Assurance Society of the United States.

249, 300

Kane & Co., care of Chase Manhattan Bank, P.O. Box Mac & Co., care of Mellon National Bank & Trust Co.,

1508, New York, N.Y...

1, 269,433 Pittsburgh..

235, 555 Merrill Lynch Pierce Fenner & Smith, 70 Pine Street,
New York, N.Y.---

1,120,927

Pitt & Co., care of Bankers Trust Co., Box 2444 Church
U.S. PLYWOOD-CHAMPION PAPERS INC.

Street Station, New York, N.Y.

808,016 May 24, 1972.

Harwood & Co., care of State Street Bank & Trust Co.,
P.O. Box 5006, Boston, Mass-

679, 300 DEAR SENATOR METCALF: Thank you for your letter of Cudd & Co., care of the Chase Manhattan Bank, P.O. May 2, 1972, regarding certain information contained in Box 1508, New York, N.Y..

509,543 our shareholder records.

Perc & Co., care of Northwestern National Bank of

Minneapolis, 7th and Marquette Avenue, MinneapoThe name of our corporation was changed from “U.S. lis, Minn..

500,000 Plywood-Champion Papers Inc.” to “Champion Inter- Chine & Co., care of State Street Bank & Trust Co., P.O. national Corporation” on May 12, 1972.

Box 351, GPO, Boston, Mass...

363,900 At the close of business on March 23, 1972, our company

Gerlach & Co., care of First National City Bank, 20

Exchange Place, New York, N. Y.-had outstanding 28,986,841 shares of Common Stock and

337,663

Credit Suisse, 8 Paradeplatz, Zurich, Switzerland. 318, 443 8,122,820 shares of $1.20 Convertible Preference Stock. Loeb Rhoades & Co., 42 Wall Street, New York, N.Y. 312,888 Your request for a list of our 30 top shareholders has been

The Comptroller of the State of New York, ITF (the considered at length, including consultation with legal

Common Retirement Fund), Attention: Director of counsel regarding the Company's right to disclose such

Retirement Accounts, Governor Alfred E. Smith
Office Building, Albany, N.Y.

265, 000 information.

Societe de Banque Suisse, Basle, Switzerland.

258, 782 We have been advised that the Company bears a

Egger & Co., care of the Chase Manhattan Bank, P.O. fiduciary relationship to its shareholders in this respect

Box 1508, New York, N.Y.

257, 976

Hare & Co., care of Bank of New York, P.O. Box 1364, and that disclosure of shareholdings otherwise than as New York, N.Y...

250, 174 provided by law, and without the consent of the owner, Sigler & Co., care of Manufacturers Hanover Trust would be improper. As an illustration of the legal limita

Co., 350 Park Avenue, New York, N.Y.

217, 162 tions imposed on us, our counsel has pointed out that even

Brown Bros. Harriman & Co., 59 Wall Street, New York,

N.Y.. a shareholder of the Company must meet certain specific

216, 159

Montreal Trust Co., Trustee of the Thrift-Stock Ownertests under the Business Corporation Law of New York ship Savings (program for salaried employees of before being permitted to inspect the list of shareholders,

Chrysler Corp. Ltd.), 15 King Street West, Toronto, including furnishing an affidavit that the inspection is not

Ontario, Canada

205, 910

Gunther & Co., 15 Nassau Street, New York, N.Y. desired "for a purpose which is in the interest of a business

204, 517 Chetco, 35 Congress Street, Boston, Mass.

200, 000 or object other than the business of the corporation ... Don & Co., P.O. Box 248, Kansas City, Mo..

200,000

Douglass & Co., P.O. Box 2010 Church Street Station, Now Champion International Corporation.

New York, N.Y..

200, 000

а

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30 TOP STOCKHOLDERS AS OF FEBRUARY 25, 1972–Continued

DOW CHEMICAL COMPANY

Number
Holder

May 24, 1972. of shares Weston & Co., care of First National Bank of Boston,

DEAR SENATOR: Your letter of May 2 written to Mr. Boston, Mass.

200,000 Herbert D. Doan has been referred to me for reply. InciUnion Bank of Switzerland, Zurich, Switzerland.. Bansco & Co., 44 King Street West, Toronto, Ontario,

178, 303 dentally, Mr. Doan is no longer President of The Dow Canada.

168, 274 Chemical Company since Mr. C. B. Branch took his place Hurley & Co., care of First National City Bank, 20

in February of 1971. Exchange Place, New York, N. Y.

167, 533 Hemfar & Co., care of Bankers Trust Co., P.O. Box 2444

I am pleased to enclose a list of our top 30 stockholders. Church St. Station, New York, N.Y.

152, 300 O'Neill & Co., Mutual Funds Department A, P.O. Box

As you will recognize, some of these are nominees and 11028, New York, N.Y...

we do not know the actual owner of the stock. Merrill

150, 000 First National Bank of Denver, P.O. Box 5825, attention:

Lynch, Pierce, Fenner and Smith, for instance, appears Trust Department.-

147, 773

on the list and while we know that they own some Dow

stock, we assume their total holdings represent hundreds COCA-COLA BOTTLING COMPANY OF NEW YORK, INC.

or even thousands of separate stockholders.

Please let us know if we can provide you any further May 10, 1972.

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

Sincerely, May 2, 1972, addressed to Mr. Charles E. F. Millard, re

PAUL F. OREFFICE, questing certain information regarding our Company's

Financial Vice President. stockholders. We must advise that we consider our stockholders'

100 LARGEST HOLDINGS As of May 1, 1972

Number names and stockholdings to be privileged and confidential

Holder

of shares information to be divulged only upon a showing of proper The Herbert H. Grace, a Dow Foundation, 414 Townpurpose in accordance with applicable provisions of the send St., Box 632, Midland, Mich.

1,006,959 law. No such purpose is indicated by your letter, and we

Trussal & Co., care of Trust Department, National must therefore respectfully decline your request.

Bank of Detroit, Detroit, Mich.

830,948

Cudd & Co., care of the Chase Manhattan Bank, Box We wish to point out that our name as indicated on the 1508, Church Street Station, New York, N.Y.

702,302 letter you addressed to Mr. Millard is incorrect. We are Sior & Co., care of Bankers Trust Co., Box 704, Church The Coca-Cola Bottling Company of New York, Inc. as

Street Station, New York, N.Y.

600,000 contrasted with The Coca-Cola Company of Atlanta,

Dorothy D. Arbury, R.F.D. 6, Midland, Mich.

567,935

A. A. Welsh & Co., Box 6147, Cleveland, Ohio. Georgia, with which we are not affiliated.

553,870

Cede & Co., Box 20, Bowling Green Station, New York, Very truly yours,

N. Y.

485,237
Merrill Lynch, Pierce, Fenner & Smith, Inc., 70 Pine
WILLIAM C. GOULDSBURY,
St. , Division Collection Unit, 7th floor, New York,

475,390
Secretary and Treasurer. Margaret Dow Towsley, 1000 Berkshire Rd., Ann
Arbor, Mich..

456,966 Thomas & Co., care of First National City Bank, 20 Exchange Pl., New York, N.Y..

453, 450 CONSOLIDATED FOODS CORPORATION Don & Co., Box 2016, Boston, Mass.

407, 134 Herbert Henry Dow 2d, 2301 West Sugnet Rd., Midland

Mich.
May 18, 1972.

397, 485

Pitt & Co., care of Bankers Trust Co., Box 2444, Church DEAR SENATOR METCALF: We have your letter of Street Station, New York, N.Y.

361, 867 May 2, 1972 addressed to Mr. William A. Buzick, Jr.,

Vada B. Dow, 315 Post St., Midland, Mich.

355, 215 Chairman of the Board and Chief Executive Officer, Sigler & Co., care of Manufacturers Hanover Trust Co.

, Saks & Co., Box 2016, Boston, Mass..

346, 288 requesting certain information concerning our Company's Þ.T. Collection AC A-56706, 350 Park Ave., New stockholders.

York, N.Y.

344, 735 While we consider the identity of the 30 largest stock- Emp & Co., care of Harris Trust & Savings Bank, Trust holders of our Company and their respective holdings to

Department, 111 West Monroe St., Chicago, Iú.

333, 456 be confidential information with which we are entrusted

Helen Dow Whiting, 2203 Eastman Rd., Midland,
Mich.

311, 012 and of which we have an obligation not to disclose without Atwell & Co., 45/47 Wall St., New York, N.Y.

288, 630 their prior consent, we are pleased to furnish you with the Calpers & Co., Box 1953, Sacramento, Calif.

271, 550 following information which may be helpful to your

Alden B. Dow., 315 Post St., Midland, Mich.

260, 898 inquiry

Leland, I. Doan, TR UW, Ruth A. Doan, 3701 Valley
Dr., Midland, Mich..

258, 849 The number of voting shares of Common Stock of our Gem & Co., Box 2016, Boston, Mass.

258, 000 Company held by 41,832 stockholders was 25,281,576 as

Schmidt & Co., care of Morgan Guaranty Trust Co. of of March 13, 1972, our most recent record date. Of the

New York, Box 1479, Church Street Station, New 30 largest stockholders, 17 are nominees, 2 are retirement

York, NY..

245, 022

Kane & Co., care of The Chase Manhattan Bank, funds, one is a publicly-held corporation, one is a major Box 1508, Church Street Station, New York, NY.. 227, 224 broker-dealer, 2 are private foundations and 7 are indi- Church Street Station, New York N.Y....

227, 224 viduals. These 30 stockholders are the record owners of

Anderson & Co., care of Fidelity Phildelphia Trust Co., approximately 31 percent of the Common Stock out- Trust Department, 135 South Broad Street. Philastanding.

delphia, Pa...

219, 065 We trust that the foregoing information will be of use

Sheldon & Co., care of The National City Bank of
Cleveland, Box 6210-N, Cleveland, Ohio..

209, 068 Yours very truly,

NY

Elsa U. Pardee Foundation, 923 West Park Dr., Mid-
land, Mich.----

203, 788
GORDON H. NEWMAN,
Carothers & Clark, Box 1910, Wilmington, Del..

198, 300 Vice President and Secretary. Rollin M. Gerstacker Foundation..

186, 568

to you.

E. I. DU PONT DE NEMOURS & COMPANY, INC. among the listed 30 represent 1.07 percent of the total out

standing voting shares of our company. May 18, 1972.

Very truly yours, DEAR SENATOR METCALF: In response to your letter of

IRA C. WERLE, May 2 to Mr. Charles B. McCoy, President of this

Secretary and Assistant General Counsel. Company, the total number of voting shares of our Common stock was 47,443,992 as of March 1, 1972, the record date for our April 10 annual meeting.

FMC CORPORATION You also requested a list of "the 30 top stockholders” in the Du Pont Company. Such information concerning

JUNE 23, 1972. our stockholders has always been regarded by this Com- DEAR SENATOR METCALF: Your letter of May 2 to pany as confidential and not to be disclosed except as Mr. J. M. Pope, our former president, has been referred required by law or regulations. A well publicized example by his successor to me for reply. of this, involving holdings we have long been required to It is our practice to respect the privacy of our sharedisclose in our proxy statements, is Christiana Securities holders, both as to their identity and the amounts of Company, a publicly owned corporation with over 8,000 their holdings, in the absence of a showing of legitimate stockholders of its own. Christiana owned, as of March 1, purpose and compelling need. 1972, 13,417,120 or about 28.2 percent of our shares. The To answer your second question, FMC Corporation balance of our "30 top shareholders" are institutions and had outstanding as of April 3, 1972 a total of 31,173,214 nominees, most of whom undoubtedly hold their shares in shares, all of them voting shares While these shares were a fiduciary capacity for numerous beneficial owners, and held by more than 30,000 shareholders, no individual whose names, if for no other reason than the possibly shareholder of record owned as much as one percent of misleading implications as to the number of real owners, them. we do not believe we should disclose.

Sincerely, I hope you will understand our position in this matter

LLOYD C. HARTMAN, General Counsel. and that the information we have furnished you will be helpful. Sincerely,

FIRESTONE TIRE & RUBBER COMPANY
H. T. Bush, Jr., Secretary.

JUNE 13, 1972.
DEAR SENATOR METCALF: Mr. Raymond C. Firestone,

Chief Executive Officer of this Company, is out of the EASTMAN KODAK COMPANY

country on a business trip and I am responding on his May 16, 1972.

behalf to your letter of May 2 to him. DEAR SENATOR METCALF: Your letter of May 2, 1972, holder list is controlled by Section 1701.37 of the Ohio

Firestone is an Ohio corporation and access to its shareaddressed to our Chairman regarding the number and ownership of the stock of the Eastman Kodak Company, particularly in light of the restrictive comments of the

General Corporation Law. As I read that statute, and has been referred to me for reply. We appreciate your

Committee at the time of its most recent re-enactment, enclosing the extract from the Congressional Record of I doubt that we are free to comply with requests from April 25, 1972, which indicates your purpose in requesting non-stockholders for information from our stockholder this information.

list. I therefore feel that I cannot respond affirmatively As you have already been informed, the law regards the

to your request. names and stock ownership of shareholders as confidential I regret the necessity of being negative in this reply, and not to be disclosed, even to stockholders, except upon but I see no alternative.

but showing of a proper purpose. We have always felt required Respectfully, to respect the right of our shareholders to be protected

JOHN F. FLOBERG, against invasion of that confidence. In response to your

Vice President, Secretary, and General Counsel. request, however, we have assembled a list of the names and holdings of the 30 largest registered holders of our

FORD MOTOR COMPANY shares. We have found, as expected, that no individuals appear as registered owners on such a list.

March 28, 1972. We can confirm to you, however, that the 30 largest DEAR SENATOR METCALF: Mr. Ford has asked me to holdings of our shares are registered in "street name" and reply to your letter of March 11 requesting a list of the the names of banks and nominees. Since this seems to be top 30 holders of Common Stock of the Company and the point you wished to make in your report on other

the number of shares held by each. companies as indicated in the Congressional Record, For reasons that I am sure you will understand, it is perhaps this information will serve your purposes. We

our policy to keep information about our stockholders would not wish to disclose the holdings of shareholder

any

confidential, except as public disclosure may be required

by law or regulation. Under Delaware law, the list of of record without his express consent.

stockholders is available for inspection by a stockholder, In response to your further question, we have outstand- but only subject to the protective provisions of the statute. ing 161,145,436 voting shares. It may be relevant to point In this instance, however, in view of your request, we put that the largest registered holdings of our shares have prepared and are enclosing the list you sought.

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