Subject:  SMALLER PUBLIC COMPANIES File Number 265-23

Date: October 7, 2005

This is my final draft,I hope you will post on for the public record.I will also put it on indymedia etc..Please ingnore first two rough drafts of rule-comments File Number 265-23

Small Compnies I sent a couple of nights ago and use or review this one.I have no editor here in Guatemala and I'm tired unto sickness but I think I got most though certainly not all typos. Becuse I know the fraud of so called small companies all too well I may not see my own typos and read right over them.Hope not.

Tony Ryals

Dear SEC,

I want to have my say and have this placed in the public records of the SEC as my statement re small companies and the ongoing anti-naked short' scam that is promoted by, investigatethesec,faulkingtruth',FinancialWire,(that Senator Bennett cited as his source that 'Global Links' was being 'naked shorted'), What I am saying is the truth the whole truth and nothing but the truth as best as I can decipher it in light of Charles Schwab,Endovasc, James Dale Davidson,attorney John O'Quinn,Judge Ken Reilly, Bellador Group of Dubai, and even the SEC with all it's attorneys and legal knowledge actually withholding as much from me as possible.And of course Stanford Uviversity and researchers Heeschen and Cooke guard their silence as well. I believe this naked short claim is organized crime even with some Beltway connection.I believe that Davidson,founder of the National Taxpayers Union, is behind NCANS just as he was NAANSS.


Besides robbing me blind, anonymous aliases on Yahoo and ragingbull who are insiders to the scam called 'naked shorting',which you surely know is a scam to divert attention from their illegal pump and dump frauds and possibly money laundering, still yell out my name and occasionally threaten my life including 'Bob O'Brien on Yahoo. And they have had my email and message board posts deleted so many times, on Yahoo and ragingbull it is a joke when I keep one for very long.All one need do is a google search of 'naanss' to find the whole story from the SEC web pages.My name,amount of losses,etc.And now around the U.S. and world on the indymedias.

By observing ragingbull and the jagh message board I knew a day in advance on February 7 that something would appear in the Washington Post the next day re 'naked shorting' although I didn't know what.Had I known anything about I would have known something was brewing as well.David Patch seems connected to and 'investigatehesec' and David Patch have a James Dale Davidson connection dating to the illegal pump and dump of gmxx.And Porter Stansberry has even recently touted Byrne's on his new website as a victim of 'naked shorting' since Brent Baker failed to convict him,Davidson and Agora Inc. for touting although they or Davidson did much worse by being CEO of Genemax and a substantial shareholder of Endovasc when they touted.Howard Hill who posts on NFI Yahoo has a Davidson connection at least loosely as they posted on the same University of Colorado website in 1999. Same for Alan Newman who are both either ncans connected or they are gurus of the naked short conspiracy of NAANSS, NCANS,investigatethesec,and James Dale Davidson. Coincidence ?

Now why would the ad be placed in the Washington Post anonymously without a Beltway connection and who would dare to do that and address their 'concern' to President Bush anonymously in this post 911 era without fear of having the CIA,or the FBI,or the Secret Service banging on their door or doing a thourough investigation of THEY MUST HAVE CONNECTIONS,DON'T YOU THINK ?

Why won't the SEC provide me with documents that pertain to the Endovasc fraud without a lot of expense or need for an attorney as the frauds the SEC has allowed to continue have eaten up 100% of my 'investment'.I speak English but do not know how to ask in legalese.According to recent newspaper articles on the SEC it appears keeping me in the dark is purposeful.When I asked Barbara Ray if I might have a copy of David P Summers letter to Dallas-Fort Worth SEC in 2004 she told me I would have to apply through foia.How do I do that ?You are all lawyers so why impede me or others who invested in a given company that loses 100% of a shareholders money yet continues in business and continues to use the internet to tout ? Why not help me ? Why help them ?

For instance you may by now have the Schwab transactions from the anonymous Endovasc account set up in May 2002 to deposit 'up to 30 million shares' into that one Schwab 'select clients' account! I am sure you have seen the pdf file with the letter from Schwab threatening me with legal action for complaining and the shareholder agreement I am mentioning haven't you ? This is in the article 'Charles Schwab and share money laundering' whose link is below.If Charles Schwab were an honest broker and did not host illegal pump and dump accounts,or least did not do so at the time they owned Schwab Capital, as the SEC has already documented, they might have fought the naked short claim to save their reputation and retrieved assets stolen from myself and probably other Schwab clients who made the mistake of 'investing'in fraudulent penny stocks,be it Endovasc or others that accused them of naked shorting to divert attention from illegal pump and activity and their own Schwab account used to conduct it.

At the very least they would not have felt an obligation to cover up for the pump and dump criminals who they hosted and let me be told by them and 'famed trial attorney O'Quinn' that I was being 'naked shorted' by Charles Schwab !

Chares Schwab and share-money laundering :

This was all done after public press releases paid by Endovasc were claiming a legit 'reverse split' in June 2002 that should have left less than 3 million shares in existence !! Schwab and probably Americans using their Schwab- LOM account,you can rest assured,are very pleased that you are allowing them to keep this illicit pump and dump account concealed.And yet you both know I have a legal time restraint on my discovery.And it's been years. And I must try to do so without money, a real constraint, wouldn't you say ? One lawyer swallowed my legal budget in one sitting.Endovasc frauds are laughing all the way to the bank,or boiler room as the case may be.Although even boiler rooms are hopefully shying away from them now.

I believed Endovasc and their and attorney John O'Quinn's claim of 'naked shorting' and was conned into buying a 'cert' from them through former SEC employee Alexander Walker's Nevada Agency and Trust Co. by way of Charles Schwab who would never even discuss the issue while Endovasc and attorney John O'Quinn bravely,now I know fraudulently,paid for a Businesswire press release stating Schwab was 'naked shorting'me immediately after what I now believe was an illegal pump and dump from a Charles Schwab account.

Also SEC attorney Ungar has already discovered that Schwab has a history of providing illegal pump and dump accounts for LOM clients which is probably where the 'up to 30 million shares' were deposited because that is or was a James Dale Davidson connected group.Strangely this is something that Schwab's Beltway located Mantas Inc. anti-money laundering 'experts' should have detected long before Mr.Ungar ! Also vFIN, that Endovasc has another undisclosed involvement with, has a LOM connection coincidentally

And as you know so well James Dale Davidson touted and promoted Endovasc in late 2002,(without ever disclosing his interest and fraudulently claiming he traded a nicotine patent that doesn't exist for an unsaid,(and unreported,in SEC filings,number of Endovasc shares),when well over one million shares were 'traded' per day for a couple of weeks.And then Endovasc and attorney O'Quinn had the nerve to say Schwab was naked shorting Endovasc rather than the truth, Schwab was hosting an illegal pump and dump account for them !! Although only a 'small company' and even after the 'reverse split' that increased insiders shares 40 times in value over night,even though the shares only reached a bit over 3 dollars in value at the height of Davidson's pump and dump of late 2002,over a million shares were being traded everyday.Even this small company ran a substantial fraud.

Other important documentation that it appears that the SEC in Dallas-Fort Worth has is the original letter from 'Dr.' David P Summers from late 2003 acknowledging the Bellador Group boiler room deal with Kuala Lumpur to Dubai connections !! How could this management,even if they are low enough to rip off their fellow Americans,do post 911 deals with a boiler room with Kuala Lumpur and Dubai connections ? And how, when it has even been acknowledged by Bellador Group and their Arizona attorney, are they allowed to keep it out of SEC filings !? Why does the government and the SEC not care ? Unaudited shares in Kuala Lumpur are probably used for money laundering !

Yes the letter released to the public on the internet has many misspellings and confusing changes to the original. But the Dallas-Fort Worth SEC officials names are correct and are SEC officials.Balador I now know is Bellador Group of Kuala Lumpur not 'Arizona.But I now know their attorney Ron Logan is in Arizona and he,like attorney O'Quinn,has made false claim of 'naked shorting' as well to cover up the shares sold or money laundered with Endovasc shares through his Bellador boiler room clients of Kuala Lumpur !!

You see this was infighting between the fraudulent Dr. David P Summers and Dwight Cantrell and Robert Johnson who seem to have authorized the boiler room deal not found in SEC filings and it appears Judge Ken Reilly who has claimed he was not on the Endovasc Compensation Committee was in on it with them.He has never denounced Cantrell or Summers for allowing his name to be placed in SEC filings as a member of that committee yet - contradicting SEC filings - he claims he never was,in email communication to me !!!

What gets me most is the SEC Dallas-Fort Worth had them and instead appear to have covered up !!!And you, the SEC sat by and let them tell me I was being naked shorted while in truth illegal pumps and dumps and,I believe money laundering itself,was occuring in terrorist suspect regions,Kuala Lumpur at least,while the SEC looked the other way!

I believe the letter to the SEC that appeared on and elsewhere on the internet by David P Summers in late 2003 to Mr. Tom Baudhuin and voice mail to Barbara Ray of the Dallas Fort Worth office of the SEC was indeed real.And I do believe it is the SEC's responsibility to audit shares and get clear reports from the transfer agents and the company management. If not,you tell me who does or who will ? And if not,doesn't this encourage not only illegal pump and dump scams but also money laundering ?


And I of course didn't have a clue when I put down my money in 2001 that Stanford would license a patent to a scam involved in ongoing illegal pump and dump activty with a number of scammy offshore crooks the SEC allowed to operate and with a transfer agent who should have been closed down years ago.Yet just look at these links - everyone knew but me and did nothing about it.Now even Mr.Lambiase of NASAA (due to LETTER WRITING OF David Patch who still hangs out on the ragingbull JAGH message board)seems to be defending such scams as victims of 'naked shorting' without checking facts.In fact Endovasc was fraudulently claiming Antonio Colombo would conduct human trials in a couple of months.

Even NASAA knew about Endovasc cyberfraud in 1999 although they would not make fraudulent claim of being victim of 'naked shorting' until they became involved with James Dale Davidson and his Agora Inc.and NAANSS and 'famed'trial attorney O'Quinn'.

How was I to know Alexander Walker was a very well paid insider to the fraud until a year after the fraudulent reverse split and pump and by James Dale Davidson through Agora and who knows what other fraudulent tout sites or mail fraud ? Mr.Walker was given a couple hundred thousand dollars in freely dumpable shares as an insider. That's good pay for a transfer agent wouldn't you say and that's only what's declared and he 'worked' with Endovasc fraudsters and many others for years.Everyone was working together to defraud retail customers ,from Schwab to Endovasc to the transfer agent to James Dale Davidson to Bellador Group of Kuala Lumpur and Dubai and I believe LOM of Bermuda as well! And yes there were others before that as Endovasc crimnial management have run several illegal pump and dumps over the years.

And these insiders to penny stock fraud and pump and dump and I believe money laundering promote shells and promises and nothing more.And they complain about the DTC but do they ever complain about their transfer agent in regards to this supposed 'naked shorting' ? Of course not.It is these well paid transfer agents who conceal the float so they can dump and manipulate the shares and share price endlessly while they tout these worthless frauds.

James Dale Davidson had a connection to most and I believe perhaps all of them as it now turns out that this founder of the Beltway's National Taxpayers Union does do business in Dubai or at least Amenni that he is recently connected to and Bellador Group he may be connected to do.Is it his Beltway connections that keep him free to defraud another day ad infinitum ? And to do deals in terrorist suspect regions with unaudited shares of U.S.penny stocks and thus unaudited money in this post 911 era ?

And to further deceive,as did Bellador Group's attorney Ron Logan who,like attorney O'Quinn,made either a fraudulent claim,or a very uneducated one,that Endovasc were victims of 'naked shorting'when no one was auditing the shares and thus no one was auditing the flow of money ? And the the only way they can lie about being 'naked shorted' is when the SEC is lax about auditing the size of the float and the criminals who run these shells called companies know it.Can you imagine an attorney for a boiler room, who doesn't even have his clients declare their shares in a U.S. company, dare claiming the unaudited shares are 'naked shorted' ? I guess you could and easily do nothing about it.

Had I not given up all privacy in order to seek the truth to the extent I could on the internet because the SEC,in its wisdom decided I did not exist and the only way to gather any information was to stay online where I was deefrauded in the first place,I would never have received email from an individual informing me that Bellador Group of Kuala Lumpur was using Endovasc shares in a boiler room in Kuala Lumpur.

The SEC Dallas Fort Worth has that information from the David P Summers letter sitting hidden from defrauded Endovasc investors like me at this very moment ! If not do a google search,'endovasc scam warning bellador'.Funny when I contacted them in 2004 Barbara Ray who Summers sent the voice mail to was polite but said I would have to apply under foia which I just didn't know how to do.For me a letter begging in English is as much as I know how to do.

But the strange thing, that at the time I thought was a good thing,was that Brent Baker of Utah SEC contacted me immediately after my communication with Barbara Ray.Funny you all have such a good grapevine yet investors can never seem to reach you as individuals by email.And now in retrospect if you consider 'Bob O'Brien' has a James Dale Davidson connection,Brent Baker is actually working for those who defrauded me in in 'naked short'' scam in the first place.And Porter Stansberry of James Dale Davidon's Agora who he failed to convict now has a new penny stock tout website on which he insinuates Byrne's is a victim of 'naked shorting' !

So the original letter I presume the Dallas Fort Worth office still has does says 'Bellador' of 'Kuala Lumpur' rather than 'Balador'of 'Arizona',but Bellador Group or does have an Arizona connection by way of Ron Logan their U.S.atorney,is that not correct ?And they are accessible even now to U.S. CUSTOMERS FROM KUALA LUMPUR OR DUBAI BY WORLD WIDE INTERNET ! So the SEC allows these frauds you have the nerve to call 'small companies' to go on and they are criminal organizations, you must know it !!!

But not all claim to be 'naked shorted' to further compound and confuse the fraud.Endovasc had already participated in many offshore schemes before James Dale Davidson and the Schwab account entered the scene.I had no idea,I thought I was investing in a with a promising Stanford patent !

Is Arizona attorney Ron Logan aiding international penny stock fraud ?

And although they may well have many scam websites they utilise two main websites for their frauds,i.e.-ragingbull and Yahoo.You know that,John Reed Stark knows that yet you do nothing.I believe your internet fraud unit busted some kid for touting in 1999,that's about all I remember about its 'work'.Oh yes and a phone tout scam more recently.Many foreigners get in on the rip off of Americans and retail investers as well.While Endovasc management,as one example, signed the shady deals that also advantaged them is was us retail purchasers paying an additional 3% to buy or sale who were ripped off.

And yet James Dale Davidson of NTU who has pulled off more penny scams than have ever been compiled is only a few kilometers away from the SEC and from Georgetown's James Angel in Alexandria,Virginia,who did a scammy videoinfomercial for ncans.And yet he claimed he'd never heard of James Dale Davidson or a fraud using 'naked short' to mask illegal pump and dump activity.He couldn't, when asked, prove a single case or point to a single example of naked shorting destroying or harming a company either,by the way !

James Dale Davidson has been the mastermind of the use of naked short claim over the internet for fraud and yet James Angel does a fraudulent video infomercial using Georgetown University for 'credibility' and yet claims to never have heard of Davidson nor any penny stock scam using naked shorting to cover it up ! Speaking of which how do you Beltway insiders keep a straight face when securities connected 'experts' like James Angel and Senator Bob Bennett go around endorsing penny stock scams whose only known or given address is a striptease club,the Cheetah Club,in Las Vegas ? And at that,besides being known for bribing San Diego officials is the only strip club I know that was investigated by the FBI under the Pariot Act ??!!

THIS IS A MASSIVE PENNY STOCK FRAUD ERRONEOUSLY CALLED 'NAKED SHORTING' THAT IS REALLY INSIDER PUMP AND DUMP AND MANIPULATION OF VERY REAL SHARES OFTEN WITH THE COLLUSION OF COMPANY INSIDERS AND TRANSFER AGENTS SUCH AS ALEXANDER WALKER .Penny stock frauds like Davidson and others select their transfer agents for their lack of ethics and they add the 'buy certs' to their naked short scam because that further compromises investors they are out to scam by tieing up their shares and making conversion difficult and time consuming.They on the other hand are experienced in certs because of their experience with penny stock companies and buing super discounted or free shares from them.I was just doing a google search of 'electronic counterfeit shares',the term may be a James Davidson creation repeated over and over on inernet scam sites and message boards like a mantra by his followers.

I am most amazed the SEC did not have an official warning out long ago that the naked shorting claim was being used for massive penny stock fraud and illegal pump and dump ops and probably money laundering because those are the facts !!! And these insiders to penny stock fraud and pump and dump and I believe money laundering promote shells and promises and nothing more.And they complain about the DTC but do they ever complain about their transfer agent in regards to this supposed 'naked shorting' ? Of course not.It is these well paid transfer agents who conceal the float so they can dump and manipulate the shares and share price endlessly while they tout these worthless frauds.

I have commented endlessly regarding small companies in general and Endovasc of Montgomery,Texas in particular to no avail.I was the 'wolfblitzzer0' on ragingbull that gave Michael Zwebner of UCSY an excuse to sue the real,Wolf Blitzer and CNN on the phoney excuse that somehow that alias was connected to them.Mr.Zwebner is a British -Israeli citizen connected to a Palestinian, Mohamed Hadid,among others,who may or may not have U.S. citizenship.That is neither here nor there.

What Mr.Zwebner has in common with Endovasc is the 'transfer agent',Alexander Walker,and his 'NATCO' of Nevada who has been both transfer agent and management in many of his various 'failed companies'.I say failed cynically because someone(s) made millions dumping shares and the U.S. and the SEC ignored it and have maintained the Reg S and other stock schemes that allow or even encourge this fraud,and I believe,money laundering as well.

And Michael Zwebner's 'companies' have 'lost' untold millions of dollars perhaps over 100 million.No one,and particularly the SEC,keeps track and have sent much or most of that 'lost' money on worthless shell companies he promotes offshore !! Some have claimed Mr.Zwebner has been involved with money laundering,I don't know,but he has certainly been allowed to run illegal pump and dump operations in the U.S.for years that defraud Americans and send their money overseas never to be seen again. And to cynically use false prs claiming sales to the U.S. miltary in Iraq and to use the tsunami victims to issue false prs all to pump and dump.I can't imagine you let this go on.All under 'small companies'.

And this is only one example as I have come to realise the depth of the fraud between offshore money laundering of illegal pump and dump schemes using U.S.penny stock shares and the facade of being small companies or 'early stage development' companies.Arms dealer Adnan Kashoggi and GenesisIntermedia comes to mind as well.And there are more,so many many more.

I had no idea.But I'm sure this is nothing new to you.No legit company can find a place at otcbb and get funding for all the frauds crowding the boards and slick pump and dump artists whose whole purpose is fraud.

The problem is that these people use U.S.penny stocks for illegal pump and dump activities to defraud the very Americans or others who 'invest' retail in U.S.penny stocks,who welcome them to the the first place. These people have international connections but I do say, in Zwebner's case,he should not nor never run any U.S. company based on past history of business failures,to be optimistic,in England alone !!!

One lesson to be learned from this is to never rely on the Beltway's Mantas Inc. to oversee anti-money laundering or anti-pump and dump operations unless you want them covered up ! How was I to know Charles Schwab, my 'broker',was hosting a pump and account for Endovasc insiders and that was why they would not answer one single question I had about 'naked shorting'?

Endovasc as well as the whole penny stock stock mafia, particularly those who ran the 'naked short' or supposed 'ant-naked short'scam, should have been in jail long ago for laundering money in terrorist suspect regions. Instead I have a feeling they will all be sending you their complaints about 'naked short selling'and how they are just little 'mom and pop' investors or companies.

Mary Campbell Helburn and 'Bob O'Brien' and the whole unidentified gang who run ncans out of a website with a Wells Fargo account in San Diego and whose only known address is a striptease joint investigated by the FBI under the Patriot Act will surely be lobbying you and congressmen in mass.

And this is who Senator Bob Bennett of Utah,and James Angel of Georgetown lend their credibility to.And this is who Patrick Byrne of supports and funds,even though he admits he's not being harmed by 'naked shorting, sort of.

The sad truth is many real small businesses who really could use the capitalization they squander either never get off the ground or can't get the loans or have to struggle with the loans to buy or produce a product.They are all parasites who are not just a drag on the economy but parasitise it.And not cleaning them up leaves them free to lie and threaten and defraud on the internet as a lifestyle.


Tony Ryals

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Has Patrick Byrne's attorney covered up stock fraud and money laundering ?

Senator Bennett:Is Patrick Byrne's NCANS A Fraud ?

Open letter to SEC and John Reed Stark on penny stock fraud

To SEC:James Angel Georgetown University aids penny stock fraud

Charles Schwab and Share-Money Laundering

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