From: Marina Kaneti [mkaneti@hotmail.com]
Sent: Friday, January 02, 2004 10:27 AM
To: Rule-comments@sec.gov
Subject: RE File No S7-23-03

TO: Mr. Jonathan Katz

VIA E-MAIL: Rule-comments@sec.gov 

RE File No S7-23-03

Mr. Katz,

I would like to express my deep concern and amazement at the proposal of a 
SHO Regulation which is to replace SEC Rules 3b-3, 10a-1, and 10a-2.

As a proprietary trader with more than seven years experience, I am a big 
proponent of the movement to change the short sale rules. In my opinion such 
rules only prevent the market to truly self-regulate itself. It is only logical 
that if a market participant is bidding for a stock, he should be entitled to 
an execution provided another market participant is willing to sell the stock 
at that particular price. A buy order should be executed regardless of weather 
the execution results in a close-out trade or a short position. 

Furthermore, ever since market participants are not required to display a quote 
of more than 100 shares (regardless of their actual order size), it is impossible 
to argue that elimination of a short sale rule would cause severe fluctuations 
and uncontrollable decline of stock prices. The actual cause for such a scenario 
should be found in the size order displayed. The notion that market participants 
can cause a crash in the stock market by shorting stocks 100 shares at a time is 
simply ludicrous!

Unfortunately the proposed SHO Regulation is written with the same ludicrous 
notion as a prime example. In reality, such a regulation will only take the 
market one step away from the self-regulating place that it is supposed to be. 
At most, SHO will only promote artificial bidding in order to create short-selling 
opportunity. It definitely does not promote or enhance market stability.

The SHO Regulation is a worthless and unnecessary proposal.
Thank you for your time.

Marina Kaneti