Subject: File No. S7-08-08
From: Ken Geis

October 1, 2008

I strongly support the spirit of the rule S7-08-08 for avoiding abuse of short selling by "naked" shorts. I have been a short trader, and I am a strong believer in the ability to sell stocks short. I think that in general, short selling stabilizes markets by creating profit opportunities around hype situations, thereby deflating the hype. Naked shorting is just plain fraudulent in my mind.

In addition, I hope that measures like this will bring some stability to the markets, making other measures (like the uptick rule and disallowing shorts on particular stocks) less necessary.