Subject: File No. S7-08-08
From: Jim P Doherty

March 19, 2008

I'm involved in the clinical and regulatory field in the pharmaceutical industry. I've owned a biotech stock called Dendreon (DNDN) for 5 years now. It has to be one of the most shorted and manipulated stocks on the NASDAQ, most of it is likely naked shorting. It has 80 million shares outstanding, but presently 40 million are sold short. It was on the RegSHO list for over a year.

I'm not an expert in securities fraud, but I am an expert in interpreting clinical trial evidence, and the naked short stock trading in DNDN, particularly as it relates to the timinig of clinical trial announcements is why I'm commenting on this naked short anti-fraud ruling.

Never in my long career in this pharma industry have I witnessed such an extent of blatant misinformation and outright lying by media outlets and/or stock analysts as I've seen with this company's clinical trial data. Between 2003-2004, very little short selling existed for this stock and fairly accurate reporting existed in the media bout this company's clinical trials. Then in mid-2004, short selling began to build. From that time until now, again and again, articles have come out under the guise of an 'independent analysis', in which clinical trial or other statistical data has been misrepresented (later to be retracted by the source, after the harm has been done). Coinciding with these misleading press reports, short selling in the stock dramatically increases. This process of negative, but inaccurate press reports or stock analyst reports, is followed by huge increases in short selling. The two have gone hand in hand, again and again over the last 3 years. Blatant manipulation seems to be the order of the day with Dendreon (DNDN).

Even when clearly positive news is released by the company, a so called 'independent' news article will say that the company is lying about its data, or other such nonsense, and the short selling will pound down any possible gain in price.

If I were uninformed about clinical trial data, I might just have to throw in the towel and assume that the market is behaving efficiently in parsing the truth from lies about clinical trial data. But this is not the case. When I know full well the accurate interpretation of clinical trial data, and then some stock analyst posts his/her opinion about this data, I can clearly see the analyst has no clue about statistics. Yet, short selling rules the day and the market 'appears' to be believing the so called 'independent' stock analyst, who in my opinion are tied directly to hedge funds perpetrating the naked short selling strategy.

So I'm left to conclude that the market for small biotech stocks that are heavily shorted, in fact, is not efficient and is instead manipulated by the huge weight put on a stock by naked short sellers, who are further inclined to pay for hatchet jobs to be printed in Associated Press releases or Dow Jones press releases. These naked short sellers are making so much money on their manipulations that they can pull out all the stops to ensure that a stocks price goes down when they want it to. This includes paying reporters to put out negative spins on a stock, or paying 'ghost' analysts to write negative reports, or to spend hundreds of thousands of dollars on selling 100 block lots of stock, like a machine gun, knocking down a stock anytime it wants.

I believe that this manipulation of the market is seriously damaging the credibility of the US market as a place to invest one's money. Illegal naked short selling by unregulated hedge funds, if it continues unabated, will surely contribute to the collapse of the financial market as we have nearly seen in the past few weeks.