Spermatophyte plants that have unenclosed, "naked seeds": The fifth extant division is the flowering plants, also known as angiosperms or magnoliophytes, the largest and most diverse group of spermatophytes. Angiosperms possess seeds enclosed in a fruit, unlike gymnosperms. In addition to the taxa listed above, the fossil record contains evidence of many extinct taxa of seed plants. The so-called "seed ferns" (Pteridospermae) were one of the earliest successful groups of land plants, and forests dominated by seed ferns were prevalent in the late Paleozoic. "Glossopteris" was the most prominent tree genus in the ancient southern supercontinent of Gondwana during the Permian
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