Bay Point, CA 94565

November 10, 2016

Via email shareholderproposals@sec.gov

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 Applied Material Inc. Proxy Statement

Ladies and Gentlemen:

There is no need to use common reason to rebut the three excuses citing irrelevant cases for exclusion of my proposal in Applied Materials’ November 7, 2016 letter to the SEC. However, to help the Company’s Board not to repeat the same baseless statements against my proposal, I would like to point out:

[A] My proposal is neither inherently vague nor indefinite. For the purpose not to “micro-manage” the company business, the proposal does not redefine the commonly used English words “improve,” “role and authority,” and “independent experts or resources” so the Company retains the flexibility to implement the proposal.

On the Yahoo! Inc. case (avil. Mar. 26, 2008), Yahoo misled to the SEC to exclude my proposal of our Chinese human rights movement. Here are some recently published coverage regarding the Yahoo Human Rights Fund (YHRF) and Yahoo’s agent Harry Wu against our Chinese human rights movement: 1, The Statement by Seven Former Chinese Political Prisoners Regarding the Death of Harry Wu and the Abuses of the Yahoo Human Rights Fund https://chinachange.org/2016/04/28/statement-by-seven-former-chinese-political-prisoners-regarding-the-death-of-harry-wu-and-the-abuses-of-the-yahoo-human-rights-fund/  (April 28, 2016): “of the approximately $14-15 million of the YHRF that has been spent from 2008 to 2015, only about $700,000 was used to provide humanitarian aid to Chinese dissidents.”  2, The Complicated and Contradictory Legacy of Harry Wu https://foreignpolicy.com/2016/05/25/the-complicated-and-contradictory-life-of-harry-wu-china-yahoo/  (Foreign Policy Report May 25, 2016): “he was ready to break rules or even laws.” 3, Champion of Human Rights in China Leaves a Tarnished Legacy http://www.nytimes.com/2016/08/14/us/champion-of-human-rights-in-china-leaves-a-tarnished-legacy.html  (New York Times August 13, 2016): “He……spending more than $13 million of the Yahoo money to operate his own foundation.”  “In some years, financial disclosure forms show that the foundation spent less than 2 percent of annual disbursements on direct assistance to Chinese dissidents or their families; in recent years, such grants all but dried up.”

The company can choose not to violate Delaware law to implement my proposal.

My proposal’s Supporting Statement is not materially misleading. It is not “spurious and born out of his [my] own personal views and biases.” For example, Stanford Business School published “Americans and CEO Pay: 2016 Public Perception Survey on CEO Compensation” by Larcker, Donatiello and Tayan in February 2016 https://www.gsb.stanford.edu/faculty-research/publications/americans-ceo-pay-2016-public-perception-survey-ceo-compensation with the following conclusions: 1) CEOs are vastly overpaid, according to most Americans; 2) Most support drastic reductions.

© The Company has not substantially implemented my proposal. From the Company’s attitude toward shareholder’s suggestion (“spurious” and “biases”), it is clear that the Company hired only one single consulting firm to provide what the Company wanted to hear so to justify the increase of executive compensation.

Shareholders have the right to vote on this important policy issue.  Should you have any questions, please contact me at zhao.cpri@gmail.com or 925-643-5034. 

Respectfully,

Jing Zhao 

Cc:  To-Anh Nguyen