Subject: File No. S7-12-06
From: RON PHOEBUS
Affiliation: INVESTOR

July 18, 2006

For me the locate requirements need to be very strict, fully verifiable with no reliance on "belief" - and safeguards that the same pool of shares are not concurrently used to satisfy the locate requirements of multiple parties.and the grandfathering of shares seems illegal its like its ok to steal or rob the public as long as they pay it back over so many years they the shoters should be put in jail for theft