Subject: File No. S7-12-06
From: Cynthia M Opp, Ms.

January 16, 2007

REVOKE THE GRANDFATHER CLAUSE 203(B)(3)(I)/RELEASE NO. 34-54154. IT IS ILLEGAL AND ALLOWS THE CONVERTING OF SECURITIES SOLD SHORT AGAINST UN-BORROWED SHARES OF STOCK INTO COUNTERFEIT SECURITIES SOLD INTO AMERICA'S FINANCIAL SYSTEM. COUNTERFEITING IS AND ALWAYS HAS BEEN AND ALWAYS WILL BE, ILLEGAL