Subject: File No. S7-19-07
From: Andreas Eisenkolb
Affiliation: Consultant

July 17, 2008

Dear Sirs,

regarding securities short sales I respectfully request you to follow the most obvious, self-evident and most simple-to-deploy principle:

a) Make it mandatory
b) for any broker participating at a securities exchange in the SEC's domain
c) without any exception whatsoever (broker, stock, period)
d) to deliver stocks sold through that brokers account
e) within a mandatory time frame of 2 days
f) actively enforcing compliance
g) rigorously penalizing misbehavior

As a result there must not be any IOU older than a maximum of 3 days in the whole SEC-domain. A reporting system needs to be installed so as to make the IOU Status accessible to the broad public.

I consider any other practice substantially deviating prom the basic principle proposed above as unnecessary complicated, intransparent and unfair.