Subject: File No. S7-19-07
From: Don Meuse
Affiliation: President, Spectrum Software

July 18, 2008

From my research I simply wish to state that it appears obvious the Reg. SHO as it exists is ineffective because it simply accepts the assurance of the broker dealer/hedge fund and leaves the door wide open to abuse.

Please enforce the requirements the same for everyone without exceptions like this.