Subject: File No. 3-13847
From: Steven Green, Ph.D.
Affiliation: Senior Professor, University of Miami

June 11, 2013

If I correctly understand this phrase within the proposed settlement "(without regard to the cost basis for those shares)", the claims paid under the Fair Fund will not reflect actual investor losses in that two people who purchased the same number of shares at two very different prices and therefore had the same holdings on 1 January 2007 would receive the same settlement even if their losses differed considerably. Such a method of calculation is manifestly unfair and only actual losses should be the basis for payment from the Fund.