Subject: File No. S7-19-07
From: Charles P. Cuffaro
Affiliation: Retired, Procter Gamble Manager

August 11, 2007

I have held several stocks which have been victimized by heavy naked shorting and failures to deliver shares which have been on the Reg Sho list. It has been difficult to hold these stocks through this excessive and seemingly illegal activity, but now it is good to see the SEC acting on this. I'm especially pleased to see the proposal to eliminate ALL grandfathering for those that have cleverly "gamed" the system.
Most of my stocks which are victims of this manipulation are in the biotech arena. The main one is Dendreon. It is difficult enough for small companies like this to get the financing necessary for the long drug testing stages as their stock prices are being artificially driven down. Unfortunately, many of them must terminate part of their drug pipeline (in Dendreon's case it was Neuvenge, a breast cancer vaccine), or they resort to cheap secondary issues or PIPE financing which then facilitates further shorting actity.
I have no problem with legal shorting, but this excessive naked short/fail to deliver issue has ruined a great stock market, and in the case of biotechs, has kept potential life saving drugs from ever getting to market.
Thank you for your attention to this matter.