Subject: File No. SR-Amex-2005-072
From: Chris Sang
Affiliation: CEO, ClairVista LLC

January 27, 2006

Silver investors should have the opportunity to invest through iShares Silver Trust. The Silver User's Association is a blatantly self-serving organization that only cares about keeping silver prices depressed. And it is not the SEC's role to limit investment options for the public.

Most silver mining companies have been losing money for years because silver prices have been too low to cover mining costs. Many silver mining companies have gone out of business. The SUA's purported concern about adverse impact on the economy and employment is a gross misrepresentation. It has been low silver prices that have depressed employment in the mining sector and closed unprofitable mines.

A free market with greater liquidity and access for silver investors would allow silver to find its natural market-established price, not a price that the SUA and its members can artificially manipulate. Also, a higher silver price would allow companies to reopen unprofitable mines and bring more supply into the market.

The aggregate silver short position on the COMEX is 5 billion of silver, representing more than a full year's worldwide production. But these short positions are NOT held by producers since silver mining companies do not hedge. They are held by a small number of financial institutions that create volatility in the futures market to profit from. Having another investment channel, such as the iShares Silver Trust, would create broader investor interest and greater liquidity in the silve market, thus reducing the ability of few participants on the COMEX to create wild fluctuations in price.

In the final analysis, the SUA is only afraid of a free market, and it's members ought to be held to public shame and scrutiny for their efforts.