Subject: File No. 4-627
From: Robert H Jenkins
Affiliation: CEO, 47 Degree North Ventures

July 9, 2011

The short position represents a quasi-derivative, enlarging the pool of shares traded for a stock beyond the scope of the SEC allowance for listing. As such, it is currently tremendously uncontrolled and cries out for oversight.

The country at one point was based on hard work and capitalistic insight as the basis for success. I'm not quite sure how we lost that. To make bets on the failure of a company simply isn't American, but for liquidity sake and the the opportunity to have opposing viewpoints, we must maintain the existence of "shorts".

With that said, the current lack of transparency in the transactions is at the heart of clandestine manipulation.
The sheer ability for one entity to sell back and forth with another entity at progressively lower prices with impunity leaves the retail investor on the outside looking in and watching investments fade for no real reason, simply a manipulated reason.

To maintain the practice, but control the landscape of the practice, three things are required:

1) An absolute limit on the number of shares that can be sold short. The amount is currently more unlimited than the actual number of shares available.

2)Transparency that shows any one entity with a short position greater than some percentage of the holding, just as required now for shares held long. This would also serve the intent of Dodd-Frank in that entities could not clandestinely short stocks on one hand and be offering the investment to others, playing both sides of the trade, without investors knowing about it.

3) Some mechanism to improve the "arms length" nature of the trades. The unfortunate part of selling between traders offers the opportunity to drive down the PPS of a stock without commensurate risk of loss - shares sold are soon bought back at lower price and the circle continues at a few pennies per trade with others occasionally jumping on shares - then only a few are lost. It is rather apparent in watching Level II trade screens to see this occur during slower trading times of the day.

Above all, I wish you luck and hope that those making the decisions on this are motivated by a free and open marketplace. Sadly, that is at severe risk right now and many who have recognized this no longer put their investments in a market that even has the appearance of being controlled - witness the Chinese companies that are being scrutinized now for accounting practices that don't meet GAAP.