Subject: File No. 265-31
From: Rose Stafford
Affiliation: N/A

April 17, 2018

I am happy to hear that you are addressing the issue of thinly traded stocks. It is important to understand that the reason that most of these "abused" stocks are thinly traded because of penny churners. If you look at the 5 year charts of most of these companies, they were trading between $20-$80 per share. Hedge funds and boiler room players come in with 300K and buy the front load, stick it on the ask and start stripping. Hedge funds like "Sabby", etc. This is a big problem, because traders see the walls they are building on the ask, and understand that they are being abused and stripped. Therefore, no one will touch them even with stellar fundamentals. Seems to me, the remedy is accountability, and creating a committee for "Fair Value". Also, Roth, Wainright and the likes use the vulnerability of financing to attain cheap shares for these funds that are churning. It's so obvious to those who watch it everyday. Case in point, look at the number of reverse splits on companies who once were trading at $50 - $80. You have professional bashers, hedge funds, bad financiers, and churners. Those are your issues in a nutshell. Best and thank you. Reference abused stocks $OPGN 25/1 reverse split, trading at .07 after reverse and $XSPA trading at .07 after 10/1 reverse split. See the 5 year chart for details. They sell every pop and churn at .10 intervals. Enough is enough