Blackwells Capital contends the entertainment and media giant should have an overarching CTO who oversees innovation. The Burbank, California-based company would also benefit from organizing its venture investments into a single vehicle, Blackwells said in a presentation reviewed by Bloomberg News.

Disney’s CTO duties are currently split between two people — one is in charge of entertainment and ESPN, while the other looks after parks and experiences. 

“Disney will never be valued as a technology firm, until it begins to think like a technology firm,” Blackwells said. 

The investor criticized Disney for underspending on research and development and said it should be investing in innovation around artificial intelligence and spatial computing.

Blackwells said the Disney board lacks directors with experience in technology and entrepreneurship. Only one board member — Amy Chang, former executive at Cisco Systems Inc. and eBay Inc. — is experienced in technology, the investor said. 

The activist investor has nominated three directors including the managing director at venture capital firm Fuel Capital, Leah Solivan, who Blackwells said can support and identify technology initiatives for companies.

Disney has a business incubator program that it’s used to mentor and invest in young technology companies for the past 10 years.

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Another, larger, activist investment fund, Trian Fund Management, has criticized Disney’s sports strategy as well as its recent investment in Epic Games Inc. Trian has nominated two directors to be voted on at the company’s annual general meeting on April 3.

Disney reiterated to its shareholders on Monday that they should reject the slates put forward by Blackwells and Trian. 

“The dissident nominees are unqualified and have no meaningful plan to deliver superior shareholder value,” the company said in a letter to investors.