Got Gold Report Comments on Proposed SEC Short Sale Rule S7-08-08

By Gene Arensberg 30 Jun 2008 at 02:10 PM

ATLANTA (ResourceInvestor.com) — I’d like to comment on the Securities and Exchange Commission’s proposed naked short selling antifraud rule S7-08-08 under the Securities Exchange Act of 1934, issued in Release No. 34-57511. The Securities and Exchange Commission needs to crack down on illegal manipulative short selling.

As Dr. Robert Shapiro pointed out in his May 8, 2008 comment, while naked short selling is presumed to be a small amount of the trading volume when compared to all volume of the exchanges as a whole, when the illegal practice is concentrated into thinly traded small and micro-cap companies it can make up a large portion of the trading activity in those issues, perhaps even a majority of all trades for those issues for extended periods of time.

Small, thinly-traded issues on

Santa Fe Holding Co., Inc. (SFHD.OB) is the parent company of Santa Fe Cattle Co., a chain of 23 casual-dining restaurants in Alabama, Georgia, Indiana, Kentucky, Mississippi, Oklahoma and Tennessee. During a recent interview, the company’s founder and chairman, Danny York, discussed the restaurant’s specific market niche and ultimate growth strategy for 2008 and 2009.

Santa Fe Cattle Co. caters to a specific niche within the steak restaurant business, with dinners priced in the $10 to $12 range, a sector that is not dominated by any one player. In this price range, Logan’s and Texas Roadhouse only operate a total of 600 locations nationwide, leaving a large portion of the market underserved and thereby creating tremendous growth potential.

Santa Fe Cattle Co’s segment of the steakhouse restaurant market falls between Outback Steakhouse and Longhorn Steakhouse, with dinners priced between $14 and $16, and Golden Corral and Ponderosa that charge between $6