Subject: File No. S7-19-07
From: James J Benham

July 21, 2008

I strongly recommend the SEC enforce all laws, regulations, procedures, and other protocols against naked short selling of any kind in any stock. I believe enforcement for only 19 financial institutions is arbitrary and capricious and gives the impression to even naive investors that the SEC has no interest in protecting individual investors. As for a more cynical individual such as myself, it brings one to think the SEC resembles a government regulator akin to those which existed in the previous USSR. I not only think prohibitions against naked short selling should be enforced, I believe short sellers should be required to have actual possession of the shares they are shorting. I believe the threshold or bar should be raised above the current requirement to simply "locate" available shares. I believe the efficiency of the markets should be sacrificed to a higher principle, that being both the perception of fairness and fair-dealing for individual investors as well as their actual protection.