From: Ken Sanders [jks@intergate.ca]
Sent: Tuesday, December 30, 2003 3:02 PM
To: rule-comments@sec.gov
Subject: Fw: File No. S7-23-03

Dear Sirs,

Re: Regulation SHO - Naked short selling.

If you can in all honesty answer that there actually is a possibility that
undeclared short selling COULD exist to the extent that it could do great
financial damage to the speculating public and the emerging Companies they
speculate in .. then you should THOROUGHLY investigate it and close the loop
holes that now allow it.

If I am able to sell, sell, sell, shares that I rarely have to deliver, I have
an absolute guarantee of illegal profitability. In other words .. profitting
from Securities Fraud.

Normal undeclared short selling by honest market makers can be justified in the
name of maintaining orderly markets.  But only if these undeclared short sales
are settled within a reasonable time by corresponding buys. The 'system' as it
currently exists leaves enough loop holes that unscrupulous criminals can work
with unscrupulous market-making brokers to abuse it on an enormous scale. In my
opinion.

The whole concept of short selling should be revised .. if for no other reason
than --Every short that is bought results in 2 people owning the same thing
without realizing it.  And that is the shareholder rights that go with owning a
share.  If all the buyers collected their votes and attended a shareholders'
meeting the holding of the vote would be an impossibility.  Surely you must
realize this.

The same goes for the distribution of any dividends or shareholder bonusses.


Thank you,

K.G. Sanders,
Surrey, B.C.,
Canada.