Subject: File No. S7-19-07
From: Vijay Kumar

September 13, 2008

You people at SEC perhaps consider yourself very patriotic but please stand before a mirror and look deeply into your eyes. By not carrying out your duties, the task you were entrusted, are you not being unpatriotic? By allowing small investor killed at the hands of short hedge funds and by allowing American companies to fail are you not doing a lot worse than what the 9/11 terrorists did? I feel really sorry having to use such words and I do so very reluctantly but your failure to act despite desperate pleas from investors and owners year after year leaves me no other choice of words. Do you realize how much pain and suffering you have caused to the people because you refuse to do the right thing? When you take home your paycheck, do you genuinely feel you have earned it?

Why do you allow naked shorts to sell non-existent shares? Will you allow long investors to buy stocks with non-existent money? You should—because the playing field should be level. If shorts can be allowed Fail-To-Deliver shares months after months then investor who buy shares should be allowed Fail-To-Deliver money for their purchase. My broker should allow me to take long position without any money as long as I undertake to make up the difference upon closing my position. Will you allow that—just so that I am on the same level playing field as the naked shorts who you allow to sell non-existent shares? But you wont. Forget T+3 days, I must put up 100% of the money before I can even place my order. So why do you allow shares to be sold unless 100% of the shares are on the table? Mind it the purchase is ALWAYS made with 100% cash even though I may be on margin. I may be borrowing part of the purchase from the broker but the seller immediately gets 100% or there is no deal. Now why dont you have the same fairness at the other end? Why is it that the naked short is allowed to sell non-existent shares? Pray why? Am I the only one who sees a totally lopsided unfair playing field here? If there ANY justification on earth why a buyer MUST put in 100% cash but the seller is allowed to put 0% goods and get away with it for days and months and sometimes years without penalties?

And what about the uptick rule? Why did you remove that? Just so that hedge funds can water-board a company to death? Is your function to protect the investing public or large hedge funds—the financial terrorists?

Please. I urge you to wake up and do the right thing before its too late and more US companies fail.

Thank you. Please do the right thing.