Subject: File No. S7-20-08
From: Nick Noecker
Affiliation: retired

August 13, 2008

What in the world is this SEC thinking of? Why are you not taking necessary steps to eliminate (not limit) naked short selling. ALL SHORT SELLING with the only exception being by OWNERS OF THE STOCK should be eliminated, unless strict controls are in place. 1: Grantor of loaned stock should be identified (the actual owner not the "STREET NAME"), 2: purchasers of shorted shares should be aware of their risk in having said shares delivered to them, 3: violators of rules should be subject to the same penalties as "insider information" violators. The manipulation of stock prices is a criminal offense and naked short selling can only be described as "PRICE MANIPULATION". This is true whether or not there is also "DISTORT and SHORT" rumors involved.

In this age of electronic transactions the false liquidity provided by specialists and market makers is counter productive and prevents the true clearing price of company shares from being established.

A market that is manipulated is not a free market.