Subject: File No. S7-08-09
From: Adrienne Najjar-Keith
Affiliation: Investor/citizen/voter

May 1, 2009

I understand what short selling is. I know how it works. However I have a fundamental problem with the entire notion of "borrowing" shares and then selling them with the promise of later returning the same number of shares - having re-purchased those returned shares at a lower price than I sold the original shares for.

Personally, I believe that one either owns shares outright, or one does not. Than means that borrowing is out. Only the bona fide owner should be permitted to sell shares, and at the going price. Shares should not be transferrable except by having been sold. The whole idea is nothing more than a gambling vehicle, just like trading in market indexes. The index represents nothing tangible. The contract is nothing more than a bet that the value will rise or fall. In my mind, short selling falls into the same category, and should be totally prohibited.

I have no illusions that the SEC will take such a radical position. The agency listens to the Wall Street high rollers, and not the small investor. As for arguments that short helps market liquidity, these are just a smoke screen to allow these gamblers to pick the pockets of everyday people like me.