Subject: File No. S7-12-06
From: Donald E Tuck

April 20, 2007

The SEC seems to be more interested in protecting short sellers than it is in protecting people who invest in the nation's companies. Why do we need a "threshold" designation for stocks that have been targeted by illegal short sales? Why not have a deadline for delivery of shares that are purchased, and require an explanation from the seller if there is failure to deliver? Your explanation of proposed rules changes repeatedly mentioned the need to protect short sellers from squeezes, but not much or anything was said about the need to protect companies, especially small ones, which have been attacked and in many cases driven out of business by naked short sales. By the time a company's shares become threshold stocks most of the damage has been done in may cases. How can you justify such a system, or the SEC's failure to protect these companies from naked shorting?
Donald E. (Gene) Tuck