Subject: File No. S7-08-09
From: Tom Davies

May 8, 2009

While I believe it is necessary for market participants to be able to take a short position on a stock, I think that currently there are inadequate safeguards in place to prevent coordinated bear raids and similar shorting mechanisms that dramatically drive down the price of a stock.

I would like to see the uptick rule reinstated, but only if it can be enforced. If another equivalent method can be put in place to reduce the extreme firepower of those who short stocks, this would be fine as well.

I also feel that hedge funds and other actors that take huge short positions on stocks should be required to reveal their identity. More transparency here would be good.

It is important that the playing field is leveled for those who wish to short stocks, as well as for those who want to invest in a stock in the hopes that the share price will increase.