Subject: File No. 4-520
From: Jim Snell

June 13, 2006

Failures to Deliver are fraud.

There may be valid reasons for a short delay and there should be monetary penalties for so doing that.

But manipulating the system to sell something that is not owned in order to collect income and not deliver (taxfree, if they can drive the company out of business) is simply fraud and counterfeiting of shares.

The idea that there is an acceptable amount of FTD's is as absurd as saying that there is an acceptable level of fraud.

Any regulator who participates in establishing or maintaining an acceptable level of fraud should be fired, tried and jailed as a conspirator to commit fraud.