Subject: File No. S7-08-09
From: Jay H Hardison
Affiliation: CEO, Interest Capturing Systems, LLC

June 18, 2009


We have developed proprietary technology that provides a market-based solution to the short-selling problems encountered during the recent credit crisis. Our technology will allow companies (equity debt) and governments (debt) both to control, and to profit from, short-selling in their securities.

Furthermore, users of our technology can set the rates at which their securities can be borrowed and can escalate those rates when there is exceptional demand to borrow their securities allowing users to make additional money when there is heavy demand to short their shares - a process that helps to obviate the demand to short their securities in the first place, as the user is now more profitable.

Our system also preserves the anonymity of the short-seller to the company or government, but we will be able to provide the company or government (and all regulatory agencies) with information about the identity of the short-seller. Furthermore, our technology completely precludes naked short-selling of securities by all companies and governments employing our technology.

Additionally, our technology will decrease greatly market/individual security volatility and will preclude the ability of speculators to pressure a security's price by buying credit default swaps, low-delta puts, other derivative instruments and directly shorting the security in an effort to drive its price lower.

We believe our technology will provide a completely market-based solution to the short-selling problems that arose, or became obvious, during the recent credit crisis.

Furthermore, our technology will allow the companies and/or governments, whose securities are being sold short, to profit directly from the borrowing/shorting process.
Thank you for your time and consideration.

Jay Hardison