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

November 25, 2007

Dear SEC, The link below leads to my most recent posts on the offshorebussiness.com message board re the naked short selling scam or claim used to distract naive or honest investors from the fact that insiders and major shareholders are dumping and or manipulating the very stock
OR STOCKS(they claim are being 'naked shorted'). I include
Roddy Boyd's NY Post article about Patrick Byrne being behind Coalition Against Phantom Trading below because as you can see it was used on ragingbull.com's JAGH message board to promote the lie or illusion that Jag Media Holdings is a victim of 'naked shorting' rather than an insider pump and dump scam that now includes Cryptometrics that promotes itself as biometrics proffessionals for New Zealand passport office but in truth is running an international fraud with U.S. penny stocks a nd allowing investors to be misled that they are being 'naked shorted' If you have not figured out by now that Gary Valinoti and David Patch are as corrupt as anyone convicted in JAGH's Burmuda Shorts set up you are asleep at the wheel. Capisce?

Some time ago SEC Chairman Christopher Cox vowed to bring journalists or those impersonatimg them for stock fraud to justice.Where is Mr.Cox now when Patrick Byrne and 'Bob O'Brien continue to pretend they are journalists and are fighting for 'mom and pop' investors ? And finally for now
I would remind the SEC from my experience of business journalists covering the 'naked short selling' broo ha ha that Forbes spread misinformation or half truths at best about the supposed business potential profits and professionalism(not)of Cryptometrics that aided the JAGH pump and dump of the last few months(that forbes naked shorting blogger Gary Weiss ignored)and this like Roddy Boyd's NY Post article below was in turn posted on ragingbull to promote their most recent illegal pump and dump AND THIS IS NOT THE FIRST TIME SUPPOSED NAKED SHORT SELLING INVESTIGATOR BOYD OF THE NY POST WROTE AN ARTICLE THE PENNY STOCK FRAUDSTERS LIKED.Roddy Boyd also wrote an article about convicted securities fraudster Thomas Ronk's
supposed naked short selling detection software(sounds something like astrology software)and Ronk and buyins.net still use the Boyd-NY Post article for self promoting propaganda.In fact the touts of ragingbull's JAGH message board still regularly post the forbes article about Cryptometrics there

Also I do not believe it a coincidence that Roddy Boyd who wrote a scam story over a year ago about 'Bob O'Brien' being 'a used medical equipment salesman' from California is cited endlessly by Steve Forbes employee Gary Weiss.Both Boyd and Weiss are employed by Steve Forbes and Rupert Murdoch and it appears both(Murdoch and Forbes) have had some involvement with James Dale Davidson founder of NAANSS and they want Weiss and Boyd to distract attention from Davidson and Agora Inc so they scream 'Phil Saunders' to avoid the name James Dale Davidson coming back in the limelight in association with this massive penny and other stock fraud just like scammy pump and dump artist scream 'naked shorting' so no one dare call it what it is - illegal pump and dump scams In fact when 'Bob O'Brien' posted a message on Yahoo'S NFI message board on June 2, 2005 stating JAMES DALE DAVIDSON DONTATED THE CELL PHONES FOR NCANS AMONG OTHER THINGS - RODDY BOYD AND GARY WEISS IGNORED IT AND BEGAN SCREAMING 'PHIL SAUNDERS' TILL NO ONE COULD THINK EDGE WISE

- Tony Ryals

http://www.offshorebusiness.com/message_board.asp

Northern Rock, Overstock.com,stopphantomshortselling.org
By harvey pitt and patrick byrne aid securities fraud on 11/23/2007 9:06:59 PM
E-mail: endoscam@lycos.com

Below is from AlanC,long time penny stock promoter on JAGH 'message board' and ragingbull.con.Just like Thomas Ronk of buyins.con he sees Roddy Boyd's hard hitting investigative journalism as free pr for NCANS and Bob O'Brien and Patrick Byrne et.al..Below that are posts from mary helburn and bob o'brien from their thesanitycheck.con discussing the newly appeared stopphantomshortselling.org website.Roddy Boyd and the NY Post seem eager to help with lies and misinformation just as the Times of London of the Lord Rees-Mogg and Rupert Murdoch was happy to plant the rumor about Northern Rock of the UK being a victim of 'naked short selling'.

Gary Weiss and Roddy Boyd lyingly claim Bobo or Bob O'Brien to be an unknown 'used medical equipment salesman' named 'Phil Saunders' and never seem surprised that their Saunders is,(with no known Beltway connections whatsoever),able to organise symposiums on the evils of naked short selling at well known Washington,D.C. hotels and have ex SEC Chair Harvey Pitt at his beck and call.Below AlanC's use of the NY Post and Roddy Boyd to promote the 'naked short selling' and JAGH fraud on ragingull.com is chatter between Mary Helburn and Bob O'Brien in which he claims to know nothing about Pitt,et.al,'s cyberfraud and mail fraud operation,Coalition Against Phantom Trading,even though we now know his partner in securities and cyber fraud Patrick Byrne of Overstock.com was behind it all the time.Jack Byrne and Jon Huntsman must be proud of the criminal minds they both helped in the formations of,i.e.- Patrick Byrne of Oversatock.com and his bought Utah Governor Jon Huntsman Jr..

Harvey Pitt should be in jail.

from ragingbull's JAGH-Cryptometrics message board.(Remember, Cryptometrics threatens to be in charge of 'biometrics' of New Zealand passport holders):
By: AlanC
23 Nov 2007, 12:15 PM EST
Msg. 90194 of 90194
(This msg. is a reply to 90193 by AlanC.)
Jump to msg. #
OVERSTOCK LOBBIES TO FIGHT SHORT-SELLING
By RODDY BOYD

November 23, 2007 -- Overstock.com is taking its bitter war to reform short-selling practices to Washington, launching a lobbying group whose goal is to raise investor awareness about so-called "phantom trading."
The group, Coalition Against Phantom Trading, is housed in the offices of Peter Mirijanian, a veteran public relations exec who worked on some of Overstock's initiatives and suggested the idea of a "coalition" to the company's lobbyists.

Mirijanian, according to Overstock lawyer Jonathan Johnson, has been trying to engage other companies on the issue and has been speaking to other lobbyists on behalf of the troubled Internet retailer. However, at this point Overstock alone is involved in CAPT.

Also involved in setting up the coalition was the company's primary lobbyist, Ken Salomon of Dow Lohnes. He secured former Securities and Exchange Commission Chairman Harvey Pitt to speak at a lunch that CAPT sponsored last Friday to publicize its efforts.

The creation of the lobbying group is the latest step by Overstock to combat what it sees as a wave of rampant short-selling that has depressed its share price. In the summer of 2005, it sued short-selling hedge fund Rocker Partners and independent research shop Gradient Analytics, accusing both companies of conspiring to issue misleading research reports.

Now, Overstock is courting politicians to aid in its fight against short-selling. Over the past year, Overstock has become an active player in Washington politics, spending $680,000, according to OpenSecrets.org. A Deseret News analysis of campaign finance records last year indicated that Overstock CEO Patrick Byrne and his father, former board member Jack Byrne, gave a little over $1.1 million to Utah politicians between 2003 and 2006.

"Phantom trading" is the term Byrne and his supporters use to describe naked short-selling, in which a company's stock is shorted without having first determined whether the stock exists or can be borrowed to complete the trade - an illegal practice.

CAPT is the latest effort by companies that have waged a war against short-selling. Two Canadian firms, pharmaceutical company Biovail and insurance company Fairfax Financial Holdings, formed the Alliance for Investment Transparency, yet their goal differs from CAPT's in that it is simply seeking greater disclosure of the short positions from hedge funds, according to Executive Director Makan Delrahim.

roddy.boyd@nypost.com

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Below,chatter between internet 'securities' terrorists Mary Helburn and 'Bob O'Brien' from thesanitycheck.con :

Re: The Most Important Thing You Will Hear This Year By mhelburn on 11/10/2007 9:33 PM
Does anybody know who is behind this?

http://stopphantomshortselling.org/

"The Coalition against Phantom Trading (CAPT) is a coalition of member companies and affilated organzations created both to educate investors about the existence and extent of illegal naked short selling and to encourage the appropriate regulatory authorities to put a stop to these trades. CAPT receives funding from a variety of sources, including parties currently involved in related litigation."

Re: The Most Important Thing You Will Hear This Year By bobo on 11/10/2007 9:36 PM
Bart: They got nuthin. Although I agree that I will likely be tarred and feathered by their quisling media choagies, which bothers me not one iota.

Mary, never heard of them. Although the enemy of my enemy is, well, at least a cautiously regarded ally.

............................................

Re: Northern Rock,Overstock.com,stopphantomshortselling.org
By gary weiss,Liz Moyer :born to eat steve forbes' mangoes on 11/24/2007 1:23:56 PM
E-mail: endoscam@lycos.com

Below is more chatter from securities terrorists website, thesanitycheck.con that even though 'Bobo' or 'Bob O'Brien' acknowledged years ago was funded not only by Patrick Byrne but ALSO JAMES DALE DAVIDSON A POLITICAL AND POSSIBLE BUSINESS PARTNER WITH THE SCUMBAG STEVE FORBES WHO MAY VERY WELL BE RUNNING PENNY STOCK FRAUDS AGAINST AMERICANS AS WELL FROM HIS FORBES' FAMILY TRUST THAT DOESN'T DISCLOSE ITS 'INVESTMENTS'.
AND WITH REASON,IF HE(STEVE FORBES) IS ALSO PART OF JAMES DALE DAVIDSON'S AND PATRICK BYRNES' INTERNATIONAL STOCK FRAUD OR
'SECURITIES' FRAUD OPERATIONS.

Note the alias Hendley probably won't be posting on thesanitycheck board much longer for exposing Mary Helburn's
lending of shares she then lies about being 'naked shorted'.
Note also that 'Bobo' then defends her fraud by saying short selling is legal This has been the whole purpose of this fraud - to confuse short selling and supposed 'naked short selling' so insiders could promote,dump and manipulate their own shares while lying about it all being 'naked short selling'.

That SEC or Securities Exchange Commission Chairman Christopher
'Naked Shorts' Cox,who claims to receive monthly briefings from the penny stock con artists at the CIA,as well as ex Chair Harvey Pitt appear to be aiding and abetting James Dale Davidson,Patrick Byrne,et.al. does not make bringing this fraud to an end very soon appear very promising.

Both Forbes boy Gary Weiss and NY Post,Rupert Murdoch boy Roddy Boyd cover up for James Dale Davidson,et.al. and point at a 'phantom fraudster' supposedly named 'Phil Saunders' as the key person behind NCANS and thesanitycheck.con..

Forbes' call girl-journalist Liz Moyer knew all along that insiders such as Mary Helburn lent shares they owned at interest in scams such as Patrick Byrne's Overstock.com and yet continued to write sensational articles in Forbes about Overstock being a victim of 'naked short selling'.Gay Weiss book 'Born To Steal' should be re-titled to ,'Born To Eat Steve Forbes' Mangoes'.

I changed the order of the posts to keep the dialogue between
'Bobo' and Hendley unbroken.I leave the posts about the Washington Times to show not only that they,like the Washington Post,are glad to aid this fraudulent 'naked short selling claim' but also because of the mention of 'share couterfeitting' in pre-computer days by supposedly printing counterfeit shares.I have searched the internet with no luck looking for such a real case scenario but have not found one.Perhaps this is a big historic cover up or perhaps those such as brokers who would more likely be given and have to identify the authenticity of paper shares were harder to dupe than individuals or small business person who could be conned into accepting say,a counterfeit dollar bill.

Nonetheless allowing this fraud,even encouraging it,as the corrupt SEC has done particularly post 9/11 is scandalous and now that the fraudulent claim has reached not only Qatar's Al Jazeera but Britain by way the Times of London and the Northern Rock scandal.Christopher Cox can pride himself on the international corruption he has helped foment to aid criminals with Beltway connections that he should be subpeonaed to identify.They are clearly NOT 'phantoms'.

Tony Ryals

chatter from and link to the Beltway securities terrorits blog,
thesanitycheck.com

http://www.thesanitycheck.com/BobsSanityCheckBlog/tabid/56/EntryID/668/Default.aspx

Re: What's $192 Billion in Fails to Deliver and Receive Among Friends?
By Hendly on 11/20/2007 11:42 AM

Bob,

Bet your proud that you allowed your NFI shares to be lent out to the short sellers.

Was it worth the 10% per month so the short sellers could drive down Novastars stock?

Hypocrite

Hendly

(Disclosure: Does not work for SEC, Hedge Funds, Sith Lords or is a reporter)

Re: What's $192 Billion in Fails to Deliver and Receive Among Friends?

By bobo on 11/20/2007 11:50 AM

Hendly: You obviously know very little about my writing or my philosophy, and yet you are clearly trying to be as annoying as possible, which makes me wonder why you are here. If you were familiar with my work, you would remember that I always took a stance that giving your enemies ammo, as in lending them your shares, was a bad idea, as they tend to require ammo to shoot you in the head, for no other reason.

Then again, none of this is about legal short selling, so that is a tangent. The reason they are delivery failures is because nobody lent anything to anyone. They failed to borrow the shares, thus stock lending or not lending is again, off point and meaningless to the discussion. Some felt that lending shares was a perfect way to supplement their income. Some, like me, felt that I didn't want anyone borrowing my shares, thus the 10% wasn't of interest.

Get your facts straight, and you will be welcome here. Keep up the inaccurate insulting rhetoric and you will be banned from the site.

Any part of that seem unclear or confusing to you? Hope it is crystal clear. Thanks for your time.

Re: What's $192 Billion in Fails to Deliver and Receive Among Friends? By Hendly on 11/21/2007 1:47 PM
Bob, I do have my facts straight. Lending out shares to short sellers drives down the price of a stock. This is whar Ms Trimbath had said during a inerview on a CFRN radio show.

Shortchanged
Liz Moyer 12.11.06

"Mary HELBURN, a Denver, Colo. investor, and many of her family are together lending 59,000 shares of NovaStar through their Smith Barney accounts. That yields income of $19,800 a month"

Hypocrites

Hendly

(Disclosure: Does not work for SEC, Hedge Funds, Sith Lords or is a reporter)

Re: What's $192 Billion in Fails to Deliver and Receive Among Friends?

By bobo on 11/21/2007 3:15 PM

Hendly: Are you feeling OK? Really, I mean, is something wrong, causing disorientation or confusion?

Nobody here is against legal short selling. Nobody is railing against prices going up, or down. This isn't the, "Anything that makes prices go down is bad" club. This is a forum which is against failing to deliver shares, in a manipulative scheme to destroy a company's share value.

Now, follow along. Legal short selling, you may like, or be neutral about, or hate. Doesn't matter to me a bit which side of the spectrum you are on.

Stock lending, which is part of that legal apparatus, you may like, be neutral about, or hate. Doesn't matter to me a bit which side of that spectrum you are on, either.

You see the word that is being used - legal? Understand that word? Not against the law? Within the established rules? Yes? No? Is the signal coming in clearer?

Now, illegal failing to deliver, which I liken to fraud (you take the buyer's money and fail to deliver the product he purchased), is used as a mechanism for illegal stock manipulation. I am against that. Very, very against that. It is bad. Very, very bad.

Note, illegal. As in, not legal.

What part of stock lending has anything whatsoever to do with illegal failing to deliver, which is not part of any kind of stock borrowing or lending? Answer: None. At all. Zero. Zip.

So we have established a number of things here. First, short selling is legal, whether you like it or hate it. Short selling has nothing at all to do with criminal stock manipulation involving delivery failures, which is what we are agin. Second, my name is not Mary, or Helburn. So wrong there, too. Third, I don't particularly object to legal short selling - god knows I can think of companies which I think suck, and which I wish I had shorted due to my sentiment - we probably all know some. But note that there is a difference between selling a stock short as a hedge or as a bet against the company's prospects, and criminally manipulating the stock down by printing shares out of thin air, in an attempt to manipulate the price for gain - illegally, I might add.

Now, if any part of this is confusing to you, I suggest you are in the wrong forum, or are just not adequately informed to have a discussion here. Nothing wrong with that, but the readers won't find any more off-point name calling of interest from you, especially given that you seem to be unclear on the concepts laid out above.

Thank you for your valuable insights, though, and may you find whatever you are looking for wherever you go next to supply your opinions.

.................................

Re: What's $192 Billion in Fails to Deliver and Receive Among Friends? By Paladin.... on 11/21/2007 1:45 PM
A great op-ed from today's Washington Times:

Phantom shares

November 21, 2007

Jonathan E. Johnson III - In the late 1800s, American financier Daniel Drew refined the art of selling counterfeit shares. Drew's biographer wrote, "There is no limit to the amount of blank shares a printing press can turn out. White paper is cheap... printer's ink is also cheap." Today, it is possible to counterfeit shares electronically and it happens with such frightening regularity and impunity that Drew would be proud.

In modern stock markets, stock ownership has been separated from stock certificates through a process known as "dematerialization." As a result, when investors buy or sell stock, they are actually trading "security entitlements" not actual stock certificates.

The Securities and Exchange Commission's Division of Market Regulation Director Erik Sirri explains: "The beneficial owner's i.e., the investor's ownership cannot be tracked to a specific share... They own a bundle of rights defined by federal and state law and by their contract with the broker. ... That's news to a lot of people." News indeed.

Brokers in U.S. equity markets receive commissions when buyers pay for shares, not when sellers deliver those shares. Thus, incentives to deliver share are so weakened that some brokers and large institutional customers (e.g., hedge funds) regularly use loopholes to avoid delivering shares at all. The result is a "failure-to-deliver" (FTD).

FTDs can be caused in several ways, but they commonly result from short sales in which the seller does not borrow or even locate the stock he sells (the infamous "naked" short sales). Regardless of how an FTD occurs, for each share not delivered the system creates a "phantom" entitlement the market treats as a real share. These "phantom shares" are supposed to be temporary in duration and few in number. Loopholes, however, are exploited on such a scale, and phantom shares are so persistent, they are corrupting the U.S. equity markets in three ways.

(1) Phantom shares warp corporate governance by inflating the number of voting shares. Bob Drummond (Bloomberg Markets) reported in April 2006, "The results of high-stakes company decisions may hinge on the invisible influence of millions of votes i.e., phantom shares that shouldn't be counted." In an analysis of 341 corporate votes in 2005 by the Securities Transfer Association, there was evidence of overvoting in all 341 cases.

(2) Phantom shares distort share prices by flooding the market with excess supply. In July 2006, SEC Chairman Christopher Cox said "abusive naked short sales ... can be used as a tool to drive down a company's stock price to the detriment of all of its investors." The creation and sale of phantom shares has become a common means to manipulate share prices in U.S. equity markets.

(3) Phantom shares create systemic risk. According to the Depository Trust and Clearing Corp. (DTCC), on any given day "fails to deliver and receive amount to about $6 billion daily ... or about 1 percent of the dollar volume." Bradley Abelow, a former DTCC director, says FTDs within the settlement system "occur as a matter of course with great regularity," and calls them "endemic." The stock market has turned into a game of "musical chairs" where claims of ownership exceed shares issued. What happens when the music stops?

In a weak attempt to curb abusive naked short selling and reduce outstanding FTDs, the SEC implemented Regulation SHO in January 2005. Regulation SHO requires the stock exchanges to publish daily a list of "threshold securities" companies that through no fault of their own have FTDs in excess of 0.5 percent of their outstanding shares. More than 6,000 companies have appeared on these Threshold Lists many for hundreds of consecutive trading days. For these companies, Regulation SHO does not work.

Freedom of Information Act (FOIA) data received from the SEC reveal that FTDs have been as high as 10 percent of the average daily trading volume on the New York Stock Exchange and Nasdaq. FOIA data also reveal that, for many companies, FTDs are a significant portion of their total shares outstanding in at least one case more than 45 percent.

Economists, the U.S. Chamber of Commerce, members of Congress, public companies, and hundreds of informed investors have urged the SEC to adopt a G.O.L.D. standard: G, eliminate Regulation SHO's Grandfather clause O, eliminate Regulation SHO's Options market maker exception L, require short-sellers to Locate and borrow shares before selling them and D, require the exchanges to Disclose fully and promptly the aggregate FTDs for every Threshold List company.

To its credit, the SEC is working to fix two significant loopholes in Regulation SHO by eliminating the grandfather clause (final phase-in on Dec. 3, 2007) and by proposing to eliminate the options market maker exception (proposed, but not yet adopted).

However, these half-measures will not stop the creation of phantom shares. Will the SEC finish the job? That remains to be seen. According to a recent Senate Judiciary Committee report, the SEC is riddled with conflicts of interest that prevent it from properly policing brokers who are guilty of securities crimes. If the SEC does not act to protect investors, it falls to Congress to adopt the G.O.L.D. standard and bring an end to market distortion caused by phantom shares.

Jonathan E. Johnson III is senior vice president of corporate affairs and legal at Overstock.com Inc., a Nasdaq-listed firm on the Regulation SHO Threshold List for 642 consecutive trading days and counting.

http://www.washingtontimes.com/article/20071121/COMMENTARY/111210005/1012/commentary

Re: What's $192 Billion in Fails to Deliver and Receive Among Friends? By ted on 11/21/2007 1:47 PM
Washington Times article on naked shorting.

http://washingtontimes.com/article/20071121/COMMENTARY/111210005/1012/commentary

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Re: What's $192 Billion in Fails to Deliver and Receive Among Friends? By hedgie on 11/21/2007 5:14 PM
Hurth also helped Byrne with an organization called American Entrepeneurs for Security Reform, LLC. The incorporation paperwork filed with the Missouri Secretary of State said the purpose of the organization was for All Legal Purposes, including educating the public and state legislatures as well as Members of Congress about the perils of Naked Short Selling in the American Marketplace. Byrne has been a vocal opponent of naked short selling, a fairly arcane stock market maneuver, and the organization paid for lobbyists in Texas to fight the practice.

Re: What's $192 Billion in Fails to Deliver and Receive Among Friends?

By bobo on 11/21/2007 5:40 PM

Hey Hedgie. when does "arcane" become "massive" or "widespread fraud"? Is $192 billion of it enough, or should we add in the multiplier that all the international fails, ex clearing fails, desked trades, etc. constitute, to arrive at more around a trillion or more? Would that still be arcane?

Isn't it funny that some journalists seem way more interested in trying to find out where the fundraising takes place for shareholder advocacy groups, than in finding out what happened to hundreds and hundreds of billions of dollars that were paid for stock, which was then never actually delivered to the buyers?

Why do you think that is? $192 billion is real money even by Pentagon scales. And yet I can't think of a single media outlet that has reported on it. But Byrne throwing some nickels at NCANS or some other group is newsworthy?

Imagine, a rich guy who is opposed to illegal stock fraud, throwing some of his resources into battling the practice. How nefarious. I mean, never mind the hundreds of billions, what's that nut Byrne doing with a few G's here and there?

Do you ever pause and wonder at just how ugly and obvious this now is, and question whether taking down the nation's economy was worth the personal gain? Or is that just too abstract for you, as long as the Maybach still comes in the colors you want?