Subject: File No. S7-19-07
From: Lars D Roose, Mr.

July 9, 2008

To whom it SHOULD concern:

We are all familiar with the expression: "It takes money to make money".

As hard as it is (especially these days) for for a working-class head of household to put aside money out of the household budget toward retirement, the kids' higher education, etc.. It is done (not without sacrifice) by those who believe in the USA and "The American Dream", and are willing to work and sacrifice extra hard in pursuit of that.

The first thing one who is new to the stock market does, is to find a company they think is in the right market for the present and future, with a sound management team too, in which to invest their sacrificed earnings in.

Then, it is time to learn about the stock market and how it works. What brokers do, what market makers do. What a "float" is, what "market cap" means.

When all this (and more) is all understood, (and if the new investor is lucky), they will also find out what "Short-selling" means, and upon hearing that it is the only thing in the universe that one can sell without first owning, the initial reaction is always the same: "That sounds like it ought to be illegal " ..

So, ok, then the rules for shortselling come into focus: "You can only 'short' on an uptick. Only 5% of the FLOAT may be legally shorted in total, on any stock. And, if one is short on a given stock while that particular company pays a dividend, then if you shorted that stock, YOU have to come up with the dividend for all the shares you have shorted."

So, OK you think, that sounds a bit crooked, but at least the rules are there and they are ENFORCED, (right?).

Then, you can see the stock market for a place to gamble too. As an investor, there are now two games you can play: 1. long term investing -or- 2. play the short-squeeze.

You have learned over time that when a stock goes up "too fast and too high", that the shortsellers (Usually multi-billion dollar offshore hedge-funds) will reach in and grab every penny of gains that is over the conservative level of market cap.., and YOU dont 'have a chance to grab those "extra" profits for yourself, so you just ride the roller coaster up and down and hopefully the general trend slowly goes up.

After a while, you can be led to think that the short selling is so rampant and creates so much volatility, that it may be more profitable to play the "short squeeze" -- where you know a stock has been shorted too much, and one bit of great news from that company will send the stock soaring overnight, so that holding the right stock for a short-squeeze like that can be more profitable than the right stock for the long haul.

And then you find out about Naked Short-Selling that is not only rampant in the market, but is routine too while the chief enforcer of the markets looks the other way.

By the time one learns all of this, they may have lost thier savings they sacrificed for years to get in the first place, and, so its back to square one for them.

You may have guessed that I am one who does not believe that "NORMAL" short-selling should be legal at all. You can say that "Well, he doesn't understand the sophistication of the stock markets and how shortselling is NEEDED to keep markets moving and stocks liquid".

Isn't it interesting the same ones who tout "Free Markets" also enable and promote "manipulated markets" ?

The stock market is already manipulated enough with normal short-selling, you don't need to also find ways to help short-sellers by giving them a tool for counterfeiting stock to short at the same time, grossly skewing the entire market in favor of the bears over the bulls.

"NSS" (naked short-selling) is a polite term for: "Counterfeit Securities".

If I were President, I would work hard to place a one-year moritorium on ALL short-selling in the markets, and then see what falls out.. but, I'm not the President.

On the other hand, why do short-sellers get subsidies (enabling) from our own market police to counterfeit stocks for shorting too ?

You may not agree with me that short-selling in general is unethical, immoral and should be illegal, but you SHOULD agree that condoning the counterfeiting of stock for over-the-edge naked shorting is no HONEST way to police a market.

In summation, what used to be the accepted norm for the stock market: "It takes money to make money" has now become: "It takes money in order to be robbed of it."

I understand that the CMKX stock I bought over a couple years, has been so NSS'd into the ground that I lost everything I had in it. I also understand that the SEC Fair Funds trust has money there that should have been released to victims of fraud in the stock market, as it has been for others who were defrauded with their (Enron for one) holdings. I want to know why the CMKX money is being held up and not released.

If this were truly a " CLEAN " stock market, I would be on the bandwagon for privatization of (some) social security money for self-directed investment. But, the way things are now, I'm sure the largest lobby for doing this are the offshore Hedge-Funds and others with the power to manipulate, who have the tools of NSS at their disposal.

Please clean this up


Lars D. Roose