Subject: File No. S7-19-07
From: Andrew W Sutton
Affiliation: Founder, Chief Strategist - Sutton Associates, LLC

July 19, 2008

I would strongly urge the Commission to enforce its already standing rule on naked short selling with the modification of requiring short-sellers to provide the borrowed shares BEFORE placing the short, not at some point in the future after initiating the position. I would also urge the Commission not to limit enforcement to certain issues or groups of issues as this only destroys the free marketplace and in the end will urge capital to seek more favorable environments elsewhere.

The current situation, while dire, provides an opportunity for regulators to shine.

Best Regards