Subject: File No. S7-12-06
From: Randall G Frakes

September 19, 2006

I have been involved in the markets since October 5th of 1987. During that time frame, I have seen several market downturns. But lets not forget, one of the most prolific bull markets of our time. The very reason that stocks move is based on either more buyers, or more a sellers in a stock, which causes it to move up or down.

By creating all of these so called short rules, or short locate, there is now a reason for way too many companys to have there stock placed on the threshold list. Ever since these rules started, it has on a short term basis caused more minipulation on a company's stock than I have seen since the peak of every bull market. And the move is based purely on the fact that there are people short the stock.

There are websites now that broadcast daily Public Releases (PR's) under the misnomer "Naked Short Alert", the apperance of every stock that is added to the REG SHO Theshold List. This addition causes an immediate volitile upward movement in the stock. This type of movement has nothing to do with fundamentals at all, and to me it is a very manipulted type of movement.

There is substantial financial incentive for any company attempting to manipulate it's own stock higher, to cause it to appear on Reg SHO. The volitility is unreal, and it's created artifically due to these rules. Stocks go up and stocks go down. If the company is doing it's part to produce good numbers, it usually stays up longer. However, there is no way to keep stocks up forever. All of these so called short sellers are getting the blame for a company's inability to run there company's profitably. Pointing a finger to distract investors has been the strategy during this time frame. It just seems wrong that the people running our markets can't figure this out so that the markets are fair for everyone.

Fair market pricing is necessary to create an efficient market. Let's keep the markets fair, and hold the management's of these company's responsible for running there company's under the laws that have been created. I don't think you ever heard Bill Gates crying over someone shorting his stock He stayed very focused and ran his company, and did so by not making silly excuses like it's the short sellers fault that our stock has dropped 25%, and not the fact that our margins also dropped by 25%.


Randall G. Frakes