Subject: File No. S7-08-09
From: Bruce Chall, Dr
Affiliation: Investor

May 6, 2009

Regarding short selling:
After the already issued shares are borrowed and under the control of the seller seems reasonable. The total stock issue is the limit to what can be shorted. Imaginary shares cannot be created to be sold short.

In the recent past shares were sold that were not controlled so ONLY MONEY was trading against issued shares of weak (new companys in need of capital, etc) companies. This is unfair to investors.

Shares were said to be borrowed but they were never delivered so multiple traders had borrowed the same shares which is just money trading against investors.

This seems so simple to me and so difficult for the public arena to acknowledge. You cannot sell what you do not control. You must borrow and have in hand what you want to sell (short) if you do not own it. You can only lend the thing you own to one other person at a time. If you lend something for others to trade you can recall that stock at immediate notice.