Subject: File No. S7-20-08
From: pcy haung

August 1, 2008

Fourteen of the most heavily shorted ETFs have short interest numbers that well exceed their respective shares outstanding. The SP Retail ETF (XRT) has a short interest figure that is more than 6 times its shares outstanding.

(My Comment: Is this another form of "abusive naked shorting'? How would the SEC explain this?)