Subject: File No. S7-20-08
From: William C Lewis
Affiliation: CFO

August 13, 2008

I am a proponent of shorting as it provides for efficient markets. That said, the allowance for naked shorting actually creates easily manipulated markets, especially on those securities that are thinly traded. This is contrary to the purpose of investing and puts stocks into the hands of day traders and hedge funds instead of investors.

Stocks should be borrowed before they could be shorted. To otherwise allow such actions allows the creation of ficticious shares in float and thus a situation of easy stock manipulation. The fact that these shares are never borrowed...and never delivered highlights how easy this process can be. With today's technology, even thinly traded shares should be able to be borrowed prior to shorting.

Further, I have witnessed companies such as UXG's shares get manipulated by shorts to first get it delisted from the Russell 3000 and now to attempt to drive the stock to under $1.00 in order to get it delisted. The SEC needs to determine whether the US markets are going to be investor focused, or day trader/hedge fund focused.