Fertilisation the Greek composite word γυμνόσπερμος (γυμνός gymnos, "naked" and σπέρμα sperma, "seed"), meaning "naked seeds", after the unenclosed condition of their seeds (called ovules in their unfertilised state). Their naked condition stands in contrast to the seeds and ovules of flowering plants (angiosperms), which are enclosed within an ovary. Gymnosperm seeds develop either on the surface of scales or leaves, often modified to form cones, or at the end of short stalks as in Ginkgo. After being fertilised, the ovary starts to swell and develop into the fruit. With multi-seeded fruits, multiple grains of pollen are necessary for syngamy with
Naked short selling a price rise. In 2008, the SEC banned what it called "abusive naked short selling" in the United States, as well as some other jurisdictions, as a method of driving down share prices. Failing to deliver shares is legal under certain circumstances, and naked short selling is not "per se" illegal. In the United States, naked short selling is covered by various SEC regulations which prohibit the practice. Critics, including Overstock.com's Patrick M. Byrne, have advocated for stricter regulations against naked short selling. In 2005, "Regulation SHO" was enacted; requiring that broker-dealers have grounds to believe that shares will be