Subject: File No. S7-19-07
From: Tony Ryals

September 30, 2007

Dear SEC
In response to Rudy Giuliani's law firm's recent comments on 'SHO' and 'naked short selling' I was inspired to do an article in reply.It is also posted in its entireity on the link below at message board but I will provide a few of my comments found therein.:

9/11,WTC,Tanya Head,Rudy Giuliani, Adnan Khashoggi,Bernie Kerik and naked short selling lies on 9/30/2007 8:55:50 PM

You can be sure that Rudy Giuliani and his Texas law partners did not write to the U.S. SEC or Securities Exchange Commission recently,(to comment on a regulation called 'SHO' )in order to ask for an end to Reg S or other SEC 'loopholes' that allow his penny stock clients and others to use anonymous offshore accounts to run illegal U.S. penny stock pumps and dumps with usually unaudited U.S. penny stock shares(and that are ideal instruments for money laundering as well).
Neither Rudy Giuliani or other members of his law firm wrote to the SEC to protest Adnan Kashoggi's,(who Rudy failed or succeeded in not convicting in Iran Contra related litigation in the 1980's),and Ramy El-Batrawi's GenesisIntermedia U.S. penny stock scam making a fraudulent claim of having its shares 'naked shorted' to distract from their own illegal activities and transactions with its worthless shares
Nor about Giuliani's ex NYPD Commissioner Bernie Kerrik's old pump and dump Taser and its false or fraudulent claim to the SEC and investors that their stocks were being 'naked shorted' as well as an excuse or a get out of SEC investigation free card played by an organized criminal group now headed by Patrick Byrne of called NCANS and before that NAANSS headed by Steve Forbes' National Taxpayers Union friend and founder named James Dale Davidson.
Funny that Steve Forbes should surround himself or find himself surrounded by common crooks or penny stock scam artists - of which Rudy Giuliani and his many penny stock clients and James Dale Davidson who even runs penny stock scams out of his and Steve Forbes' National Taxpayers Union in Alexandria, Virginia not far from Chairman Christopher 'Naked
Shorts' Cox's U.S. Securities Exchange Commission office from where he presides as a sort of master of ceremonies over all this fraud.

Although Rudy Giuliani's law firm prides itself in representing scammy investor unfriendly penny stock companies and white collar criminals for large fees , Rudy appears to have completely missed the role U.S.penny stocks played in 9/11 and the WTC tragedy.
Both ICTS International and Securacom - although capitalised by ultimately defrauded mainly American retail penny stock investors - were both chiefly foreign owned and controlled companies that guarded Lgan Airport,Dulles Airport,the WTC,etc.,on 9/11 In effect those who Rudy Giuliani's law firm or lobbying firm would advocate for would keep in place the penny stock fraud that capitalised and brought us both the Israeli ICTS International that 'protected' Logan Airport on 9/11 but also the Marvin Bush,Wirt Walker III and Al Sabah Securacom that ripped off investors and 'protected' the WTC on 9/11.

Mr.Giuliani never even realised that supposed WTC survivor and activist Tania Head was a 9/11 fraud just like himself While Tanya Head practiced for many years at being a WTC survivor her leading rival in post 9/11 fame or infamy as the case may be,was Rudy Giuliani,an unpopular NYC Mayor who had made a miraculous post 9/11 comeback along with his police commissioner Bernie Kerrik. Rudy Giuliani so full of himself and determined to promote or 'pump' his rising Myth American status never really noticed the holes in Tania Head's tale of survival in the WTC perhaps because he was too busy covering up his own.

Rudy should have known enough about penny stocks
to have NOT mistaken the Israeli connection to 9/11,Logan Airport near Boston Massachusetts and his city's now destroyed WTC building And Rudy should have been the first to have used his legal clout to close ICTS International run by a convicted Israeli and friend to Prime Minister Ehud Olmert named Menachem Atzmon that was and is a penny stock fraud and possible money laundering operation to this day And yet that company's stock has remained trading even on NASDAQ until only very recently It was defrauded American investors who were conned into buying ICTS International shares that allowed the incompetent and fraudulent Israelis to buy Huntleigh airport rent-a-cops and the contract to guard Logan in the first place

Meanwhile Securacom of the Kuwait American or better put Al Sabah Bush Company was another 'security' scam and penny stock pump and dump of the 1990's with Marvin Bush hid cousin Wirt Walker III and a member of Kuwait royal Al Sabah family on the board.They had the supposed jobs of guarding the WTC as well as Dulles and Reagan Airports on 9/11.

And this is the kind of 'business' Rudy Giuliani and his law firm are defending now by writing the U.S. SEC in favor of penny stock clients they directly or indirectly represent You will perhaps recall Rudy had the responsibility to prosecute Adnan Khashoggi over the years and always somehow blew it.Now paradoxically in writing to the SEC in favor or lobbying for the penny stock naked short claim criminals his firm is not only covering for the stock manipulators of Taser stun gun folks that gave his ex partner Bernie Kerrik so many shares to sale to or dump on investors but also paradoxically his law firm is covering up for Adnan Khashoggi and his old pal from Iraq Contra days Al Batrawi who also claim their clearly fraudulent pump and dump company GenesisIntermedia was also a victim of 'naked shorting' Both Bernie Kerik's pals at Taser and Adnan Khashoggi partner Al Batrawi have lied outright about being 'naked shorted' to cover up their own fraudulent manipulation of both companies shares.

Where's the legendary Rudy Giuliani when you need him ? The myth of his success has all been mysteriously enough the results of his FAILURES He failed to bring Adnan Khashoggi or any other George Herbert Walker Bush and Iran Contra or Iraqgate connected criminals to justice or even get Ollie North for even one of his many penny stock
And Adnan Khashoggi walked because Rudy Giuliani failed to convict him.

If Giuliani were to succeed to the White House he might go down as the biggest loser to arrive there yet and considering the rePUTAtion of of his would be predecessor George W Bush - that is saying something.But W Bush the loser and failure and destroyer - sort of,kind of inherited his royal position of Nero without a fiddle while Rudy Giuliani can say he earned his by the sheer heights of his own failures.

The WTC and New York terrorist attack of 9/11/01 was like Rudy Giuliani's falure to convict Adnan Khashoggi in the 1980's - among his greatest successes.The New York Mayor's 9/11 celebrity status and national media publicity sent his national popularity rating 'to da moon' as they say in in penny stock tout or promotion land and on internet
'message' boards.

Yet how did Rudy Giuliani,an ex U.S. Attorney and politician for whom appearances are everything,not catch the inconsistancies in Tania Head's story of her survival at the very top of the WTC ON 9/11? In fact how could not Merrill Lynch have spoken up long before now and said they had no employee by her name ? Or Stanford University where she claimed to have attended ? But Rudy took it all with a straight face and stiff upper lip - after all if he never noticed holes in Miss Tania Head's story as a WTC survivor - well - he surely knew her myths or lies aided and abetted his own.

Steve Forbes who has always wrapped himself in James Dale Davidson's National Taxpayers Union as if it were the American flag has officially endorsed yet another penny stock parasite for the U.S. presidency.