Subject: File No. S7-12-06
From: Randall T Goff

April 11, 2007

Eliminate the "grandfather clause" immediately....SEC has no right to allow conterfiet and generation of bogus shares, that were conterfited prior to Jan 2005 to remain eroding our market.

The grandfather clause is an ilegal manuplation which continues to allow off shore hedge funds and others to pillage the American economy.

SEC as our only regulator, should never have allowed such a fraud to happen in the first place.

We are now in the process of recinding a SEC perk to those that ilegally sold shares that they did not own, in turn causing the American investor and some companies to lose hundreds of billions of dollars, driving many companies out of business.

We are now jumping thru hoops to get recinded that,that was thrust upon us with out any request for comments or other public inputs, however to get it recinded we are now in our second comment period, which is nothing but another stall tatic by the SEC.Time to GET IT DONE.