Subject: Regulation SHO

July 16, 2008

Ladies and Gentlemen:
As drafted and enforced, regulation SHO is systematically ignored, circumvented and abused. The operative rule for ALL securities should be the one recently imposed with respect to the shares of Fannie Mae, Freddie Mac and the primary dealers: preborrow the stock -- no exceptions. Rules changes and the absence of SEC market enforcement in recent years has created a market characterized by unprecedented volatility and predatory practices not seen since the 1920s. It's time to clean it up. Sincerely,
H.W. Shaeffer

H. W. Shaeffer, Esq.