Subject: File No. S7-19-07
From: james brownlow

July 18, 2008

I would hope that naked short selling would be illegal for all stocks and enforced, especially small caps. The use of foreign exchanges, especially Canadian and German, to evade regulations is troublesome,and should be prohibited. The up tick rule should be re-instated and brokers required to have shares before shorting is instituted or they not be permitted to deal in that security until shares are obtained. Naked short selling is totally undermining confidence in our markets and for good reason. Please stop it