Subject: File No. S7-08-09
From: Josh Levine
Affiliation: Founding Editor, The Vietnam Business Journal, a magazine for western investors that chronicled the economic transformation of Vietnam and SE Asia from state-run to free market

May 11, 2009

I appreciate the opportunity to voice my opinion on this. I believe that short sellers perform a service that is one of the more efficient tools developed by free market economics, with regard to the art of valuation.

Short selling is the only safeguard imaginable that enables well-informed, sophisticated investors to counter false or misleading information originating from a listed company, government entity or other party with an interest in boosting a stock or sector.

As an exquisitely efficient mechanism enabling its users to benefit from information or instincts that are potentially superior to those otherwise available from designated institutions of transparency: journalism, investment banks, rating agencies, and government, short selling ends up as a powerful and instructive voice, in the context of free market principles, a stepchild though it may be.

If the investment rule of thumb is true that "the biggest fish are caught in the muddiest waters," then short sellers cast rays of light and clarity on markets that are so often just mud on mud on mud. Heaven for bottom feeders -- but risky and dispiriting for the ordinary investor.