Subject: File No. S7-08-09
From: Ken O'Shell

February 20, 2010

Short selling puts most private investors at a disadvantage because the average investor doesn't understand short selling and there are restrictions for short selling in many types of accounts, like 401K and IRA accounts. Short selling is all about how much buying pressure is on a stock and general market sentiment. In many cases, it has little to do with the true value of the stock being shorted. I agree with many analysts who think that short selling contributed heavily to the recent market crash. Short sellers fuel negitive sentiment to create a market environment to paralize the average buyer, then drive stocks down and cover with call options to lock in profits. This is not right and needs to be corrected.
I think there should also be restrictions for brokerage firms who loan stock that I purchased for the purpose of short selling WITHOUT MY PERMISION.
As you can see, I am very much in favor of placing as many restrictions as possible on short selling. Eliminating the UPTICK RULE has increased the instability of the market.