October 7, 2005

Subject: File No. 265-23,

Regulation SHO is a sham. Stop playing with criminals and enforce the laws that have been on the books since the great depression. Manipulation of small investorís wealth is rampant. This has all transpired on the SECís watch. Grandfathering malfeasance is certainly not the answer. All fail to delivers should be bought in by day three, not 180 days and counting. The DTC must be brought to heel. Proxy votes are meaningless when shares are diluted by counterfeit shares. Short interest must be reported on a daily basis not monthly. Hedge funds need to be more closely regulated in the interest of transparency.

Thank you for letting voice my opinion.
Don Develder