Subject: File No. S7-08-09
From: Anthony M Lukacek, R. Ph C.P.

June 22, 2009

Criminal counterfeit of shares are caused by the 3 day rule not being followed. Especially Reg SHO. not enforced.

Lilly(LLY) Average daily Volume (3 month) 6,182,240
Short % of Float (as of 26-May-09)3 2.1 %
Shares Short (prior month) 24.16M

Shares short almost 4 times the average daily volume More than 3 days of trading
This alone should tell you the 3 day rule is not being followed. Just look at key stats of companies.

These do not reach Regulation SHO short positions and are not reported. ALL need to be handled Now.
These short position are far in excess of the 3 day return obligation period.
These enduring short positions are caused by someone turning their heads

Main elements in naked shorts decreasing share price is:
Crucial element created by Market Makers, brokers
ETC complacency, incompetence and deal making (greed)
and lack of oversight or/and unwillingness to enforce
the law.
2. INCREASED SELLING. A naked short can help his own cause

3 days is tough for information to get out and affect a stock. If it is stunning information, usually the stock is halted until everyone knows.

Does a naked short really have to have any information? No
All a naked short has to do is sell what is not possessed by counterfeiting stock. A paper IOU
Polite and elusive term not understood by most, FTD = Failed To Deliver.
This term FTD = Failed To Deliver gives an air of legality to criminal counterfeiting of shares..
Oh, it just got failed to deliver. Ok. It is NOT OK......

If I and a lot of other people understand this, you should.
What is taking so long? The law is in place. Why are more hearings necessary to implement it?

If I do not get my account square in 3 days, I am penalized. The hammer falls.