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'Tis A "Bootless Labour" To Ask The Staff To Appeal Its Own No-Action Advice

2015-01-13 06:05:25| Grocery - Topix.net

In This "Appeal" Of Whole Foods' No-Action Letter Isn't Very Appealing , I wrote about Jim McRitchie's attempt to "appeal" the staff's decision with respect to the exclusion of his proxy access proposal to Whole Foods Market, Inc. The staff had concurred in Whole Food's position that it could exclude the proposal under Rule 14a-8 . Mr. McRitchie "appealed" directly to the SEC even though there is no formal procedures for such an appeal.

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