Subject: File No. S7-08-09
From: Parag K Sanghani
Affiliation: Senior Analyst, Hedge Fund and CFA Charter Holder

May 19, 2009

Market volatility has increased since the uptick rule was removed, however, we just went through a rare event where our financial system almost collapsed. I believe that in a normal market enviornment, the removal of the uptick rule would not cause higher volatility.

I believe the best way to stop predatory shorts is to require each shorter to secure a borrow... set up the systems to track that shorters have a borrow before they are allowed to sell.