Subject: File No. S7-25-06
From: Darren Unruh
Affiliation: President, Watchmaker Capital Management, LLC

February 13, 2007

February 13, 2007

To the Commissioners of the SEC:

As a follow up to my comments dated February 5, 2007, I raise the following issue:

Fortress Investment Group (NYSE symbol "FIG") is a publicly traded company. Last week, it went public at $18.50 / share and closed at $31.00 / share after the first day of trading. Today, FIG closed at $28.90 / share.

The key here is that FIG is, primarily, a manager of hedge funds. Since a significant portion of FIG revenues are derived from performance fees charged for profitable investments, all shareholders of FIG are economically exposed to many of the same opportunities and uncertainties of being a hedge fund investor ... even if they are not accredited.

Is the Commission suggesting that it is appropriate for all investors who wish to invest in stocks to consider FIG alongside all other publicly traded stocks, while only a portion of the investors can actually invest in one of FIGs investment offerings?

Question: What is the difference in these ten financial transactions:
Buy stock in Ford; buy a Ford Mustang
Buy stock in Dell; buy a Dell computer
Buy stock in Six Flags; visit a Six Flags theme park
Buy stock in McDonalds; buy hamburger from McDonalds
Buy stock in Fortress; invest in one of Fortress' investment offerings

Answer: Only one of the ten has governmental restrictions.

Relatedly, Fortress isn't the only firm that generates a significant portion of its revenues, or protects or hedges a significant portion of its revnues, for the firms' owners through it's activities in the capital markets. Other firms that rely on their capital markets activities to make or protect significnat portions of their revenues and/or their assets include:

Goldman Sachs (proprietary trading, hedge fund fees, asset management fees, brokerage commissions, etc)
Exxon Mobil (oil and gas trading and hedging)
Bank of America (loan syndication, trading, brokerage, asset management, etc)
Berkshire Hathaway (equity, fixed income, currency, metals, etc. trading)
Newmont Mining (gold)
Fannie Mae (interest rates)

Since the Commission desires to restrict the access of small investors to hedge funds (like the ones that FIG manages), is the Commission going to examine the propriety of small investors making investments that are tied to the success of other professionally managed entities' activities in the capital markets, as well?

Thank you for considering this natural extension of the logic underpinning proposal S7-25-06.


Darren Unruh
Watchmaker Capital Management, LLC