Subject: File No. S7-08-09
From: Christopher j D'Ambrosio
Affiliation: Director of Equity Trading

May 10, 2009

I have been a registered equity trader and market maker for 15+ years, and have see a lot of changes made to our markets....some good, but most bad.

There is a lot of discussion about rules to curb or control short selling. From someone in the middle of it, I think I have fairly good knowledge of what work and what doesn't. In my opinion, re-instating the uptick rule would definately help curb the abuses we have seen on the short side, but the bigger issue is being missed. Even without instituting the uptick rule, you could curb abusive short sale practices by simply ENFORCING the existing rule relating to the borrowing of stock and naked short selling. Short selling on its own can be part of a healthy market. However, NAKED short selling is nothing but a deliberate abuse of the existing rules, flaunted brazenly in the face of the SEC, without fear of retribution.

The original rules worked well for this market, and were originally put in place for good reason. Use them, don't just create newer ones. And worst case, do nothing but enforce what you already have.

Thank you.

Chris D'Ambrosio