Subject: File No. S7-08-08
From: Dean A Eckstrom
Affiliation: self

July 20, 2008

This rule does not go far enough. I find All Naked Short Selling offensive, it undermines the value of all long holders like myself.

As evidence I hold up the increases in share value of the 19 companies you have banned the practice through July 29. I see little value in short selling in general, but moreover naked short selling invites fraud and abuse and demonstrably lowers value for long holders.

I can not for the life of me understand How you selected the 19 companies for the temporary rule. It seems extremely biased, unfair and unethical. You can not even temporarily do this for any company, and not do it for all.

I wish you would broadly expand rules preventing naked short selling entirely, not merely the narrow definitions contained in this rule. Trying to prosecute the narrow definitions in the rule will prevent it from having much utility. Why should long holders be subject at all to the speculative pressure of individuals who can not demonstrate that they even possess any stake in the items they trade.