Overstock won and proved that their stock was being naked shorted but it wasn't easy, took a long time and cost them a lot in legal fees. Furthermore they got lucky when the lawyers for the shorts screwed up and made public information they did not intend to. They should not have had to go through all this but the regulators do not enforce the rules and regulations. Just enter GS and fines for naked short selling in your search engine and read what comes up. Go IPIX!!!