December 29, 2021

December 29, 2021 . Stephen L. Burns . Cravath, Swaine & Moore LLP . Re: International Business Machines Corporation (the “Company”) Incoming letter dated December 27, 2021 . Dear Mr. Burns: This letter is in regard to your correspondence concerning the shareholder proposal (the “Proposal”) submitted to the Company by James McRitchie (the ................
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