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Jim Bishop

03/11/06 3:04 PM

#82555 RE: Mark_Leh #58036

A question Mark (hehe) for you, or anyone. I'm confused.

I just noticed something...better late than never I guess.

I thought that since April 14/05 ALL OTC stocks were to be included on Threshold Lists and could show on SHO if the FTD's meet the criteria.

I thought that because of this:

"Additional OTC Securities subject to Regulation SHO for January 20, 2005 to April 13, 2005. Note: As of April 14, 2005, all OTC Securities have been included on the Threshold Security List."

http://www.nasdaqtrader.com/aspx/regsho.aspx

However, the only pinks that seem to show up on SHO are one's that either currently file or have filed in the past.

I notice this on SEC SHO faq pages.

"Reasons Why A Security With a Large Short Position May Not Appear on a Threshold List

There are various reasons why an equity security with a large short position may not appear on an SRO's threshold securities list, 25 for example:

- the aggregate delivery failures do not meet the definition of a threshold security in Regulation SHO;

- the security's issuer is not registered or required to file reports with the Commission. For instance, the majority of issuers quoted on the Pink Sheets do not file reports or register with the Commission, and so would not appear on threshold lists.

http://www.sec.gov/spotlight/keyregshoissues.htm

LFWK say in news that insiders alone own more than the issued and outstanding. LFWK do not show on SHO. While they have never filed financials, 8k's etc etc, they do have a initital REGDEX paper filing.

My question: is that filing not enough for them to qualify as registered or required to file reports?

If so, and if they are correct with their news which indicates that FTD's should be well over .05%, the only reason I can see for them NOT appearing on SHO, is that the SRO does have enough verifiable share structure information to calculate the % fails.