October 4, 2005

Subject: File Number 265-23

File number 265-23

Dear Committee Members,

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

The apparent unconcern of the SEC on the huge volume of 'fail-to-deliver' we see daily on the Reg SHO lists has long passed the level of scandalous. The impression the SEC gives is that it is more concerned with protecting the interests of those participating in this activity than with the interests of the investing public.

We urgently need more transparency and accountability, including toward hedge funds.


Philip Bursley
El Paso, Tx.