Subject: File No. S7-08-08
From: Patrick Call

March 26, 2008

This "new" Anti-Fraud Rule that determines who is liable in FTDs is a nice start, but it basically now just pointing a finger, whereas before we had two entities pointing fingers at each other. So I guess that is at least a start.
So what are you going to do about it? Are you going to enforce the rule? You don't enforce REG SHO, what makes us think you are going to enforce this additional rule?

You have sucked the confidence Americans and foreign investors have in the Markets with all these rules you have made, but not enforced.

This current rule "highlights illegality" of abusive short-selling. Thanks for making it bright red now instead of black and white like it was before.

This proposed rule "could help reduce..." illegal short selling. How about you come up with a proposed rule that "WILL REDUCE AND ELIMINATE" illegal short selling It is this exact wording that undermines my confidence in the SEC as a regulator over these markets.

Abusive naked short selling IS illegal--relationships of brokers and their "prime" clients, the impact on liquidity, the induction of selling to be executed overseas should have no bearing on how aggressive you are in upholding the law.

Please follow up this proposal with another proposal that actually makes illegal short sellers COVER their existing shorts or not be able to enact them in the first place.