October 4, 2005

Subject: File Number 265-23


The SEC has apparently been deaf to the numerous complaints in the past year on the multiple uses of 'naked-shorting' to obviously manipulate the prices of small cap equities. Many small companies and their investors have been ruined by this practice.

The apparent unconcern of the SEC on the huge volume of 'fail-to-deliver' we see daily on the Reg SHO list is rapidly approaching the level of scandal. The impression the SEC gives is that you are more conerned with protecting the interests of those participating in this activity than you are with the interests of the investing public.

We need more transparency and accountability.

With respect,