Subject: File No. S7-12-06
From: Noga Rosenthal

April 19, 2007

Although I understand the conceptual "unfairness" in naked short selling, I would think that any price difference resulting from naked short selling is not only limited, but short-term. Regulations should be based on hard data, which is available in this case. Until we see that data, any argument for or against naked short selling based on its effects are mere speculation.

Noga Rosenthal