Subject: File No. S7-19-07
From: Harry V Cumberland, CFP
Affiliation: RIA representative Branch Mgr, Raymond James Financial Services

July 19, 2008

I am NOT concerned about short selling when LEGALLY performed by borrowing shares in the proper manner.

"Naked Short-selling" is a crime against shareholders because it effectively increases the supply of stock, thereby reducing its value.

Laws against the practice have large loopholes and are not taken seriously by brokers-dealers.

This practice of "Naked Short-selling" has been going on for many years and in some cases has driven companies out of business by destroying credibilty and the company's ability to raise investment funds.

I see it as a real and ongoing problem against smaller companies in which individuals, not just institutions are
harmed by effectively "watering the stock" (more shares are trading than authorized).

Make the law enorceable and then enforce it in the name of fairness and justice