Subject: File No. S7-19-07
From: Roger C.

August 14, 2008

Please propose a stricter standard to preborrow shares. This will have a positive impact on smaller, less liquid securities that may be hard to borrow and easier to manipulate through naked short selling. I own GBTS, which currently has 1,284,950 shares short as of 7/31/08. There is a failure to deliver in shares of GBTS. Naked short selling is unfairly pushing down the value of GBTS.