Subject: File No. S7-19-07
From: Gary Engler
Affiliation: ERC

July 16, 2008


Anyone selling securities "short" should have to obtain "good title" to those securities before the date and time of the "short sale". No exceptions, Grandfathers, or other slight of hand boloney. As soon as exceptions are allowed, the short sellers become "in control" of the destiny of the underlying security price by definition. This is patently unfair to the investors in the underlying security and the company that the security represents. This kind of depressive pricing control must be stopped. Risk is risk and the short seller does not have risk if he is not the title owner of the borrowed security.He is playing games with other peoples lives and livelihood.