Subject: File No. S7-12-06
From: James R Scummer
Affiliation: Senior Equities Strategist

September 6, 2006

Dear Sirs, I am writing for the abolishment of Reg SHO. While I'm at it I would like to see ALL Securities Laws repealed. Especially that pesky Rule 10b-5 of the Exchange Act that deals with manipulation. See, I'm a naked short seller. My 1 goal is profit. My techniques are very straight forward and are described on the SEC website:"Selling stock short and failing to deliver shares at the time of settlement with the purpose of driving down a security's price." I feel I'm entitled to guaranteed profit. That's why I manipulate the laws of supply and demand (supply specifically) to guarantee a stock will decline in price. Sure, I claim I'm looking out for the little guy in exposing "scams". OR that Reg SHO is a "hindrance to price discovery or sell side liquidity". But, make no mistake. My goal is to profit from manipulating stock prices. If that means a buyer of our newly created stock receives nothing in exchange for their cash,so be it. I am entitled to a guaranteed profit. I would also like to put in a good word for my friends at NITE Securities. They trade billions of shares of .0001 stocks with no spreads and NIL commissions. WHY you ask? The answer is in the almost $200 million in customer fails they've had the last 2 quarters combined. They do a great job.
Well, I'm off to manipulate a few more stocks today. Keep up the good work. Oh, I almost forgot. When Chairman Cox said: "From the standpoint of orderly markets, it's VITALLY important that shares be delivered. These are CONTRACTS and they HAVE to be fulfilled." He wasn't serious was he?
Sincerely, James R Scummer Senior Equities Strategist, Scummer,Scummer and Scummier, Jersey City NJ