Subject: File No. S7-31-08
From: Kevin D Cundy

November 7, 2008

Re: Release No. 34-58785 34-58773 respectively.

I would like to thanks the commision for the opportunity to comment on the above two proposed rules as set forth by the commission.

But I must state first that I have not taken the time to bother reading either proposed rules, as I have read all previous rules reguarding naked short selling,penny stock rules, fails to deliver, Regulation SHO, et al, and have found all said rules so full of loop holes, and back doors, as to render them a joke to REAL regulation and reform.

As to your newest crop of proposed rules and regulations, let me start with YOUR initial wording of the time frame of these rules, if I can even call it that.

"interm,final,temporary" ?????

I ask, do you people even have a fundamental grasp of the english language?

Now onto the proposed rules themselves, of which I'm sure contain more than enough loop holes to drive a large Hedgefund through.....

I will not waste my time nor insult my own intelligents by reading them as I have no doubt they contain many of the same sort of wording and loopholes to allow the same individuals and institutions to continue to game the system and steal from avearge investors and small public companies.

I will say only this... the current state of the financial economy of the entire world is now in shambles due to one....and only one reason...

THE ABILITY OF INDIVIDUALS AND INSTITUTIONS TO SELL SOMETHING MORE THAN ONCE OR MULTIPLE TIMES TO MULTIPLE BUYERS, AND/OR THE ABILITY TO RESELL THAT HIGHLY DILUTED ITEM ONCE AGAIN TO A THIRD PARTY FOR PROFIT AS A "REPACKAGED" NEW SECURITY.

I ask myself repeatedly, " when is somebody at the SEC going to see the light" ?

Thank you for your time.

Kevin Cundy