Subject: File No. S7-20-08
From: David G. Funk, Ph.D.
Affiliation: Former Asst. Prof essor of Economics/ Privaate Investor

July 24, 2008

Please extend permanently, to all stocks, the ban against "naked" short selling covered in your release 2008-143.

There is irrefutable evidence that naked short selling can and does take place even though it is illegal. Please aggressively enforce a rule against such activity.

Short selling, without first borrowing stock to short against, is the equivalent of having a printing press and printing an unlimited number of shares not properly authorized by the subject company.

If the printing press were printing money, the activity would be called counterfeiting. If it is effectively printing stock certificates, it is called "naked shorting". Either way the activity is illegal and unethical.

Also, please make regular reports as to "fails to deliver" conveniently available to the investing public. Presently, to my knowledge, such information is only partially available to the public with substantial and self-defeating expenditures involved.

Thank you for considering my comments.

David G. Funk