Subject: File No. S7-08-09
From: John L Parmigiani
Affiliation: Registered Investment Advisor

February 20, 2010

This proposed rule is against everything the stock market Stands for. The reason why the indexes always trade higher is because in reality, the market is a rigged game. When an index component is having fundamental issues, it gets replaced with one that is doing better. That's why the indexes historically go higher long term.

If a public company is doing poorly,the same way you have the right to pull it out of an index, it is our right to short sell it to zero. Every high ranking executive of a large corporation makes his/her net worth off the stock that they own when things are good. Why should they continue to keep that wealth when things aren't good?

The markets are built upon being able to play both sides up or down. It would not be right that when a company is irresponsible, its shares should not be punished. You should consider forcing top level executives to reinvest the hundreds of millions some of them have made back into those companies to keep them afloat rather than hitting tax payers for it.

The short side of the market is very prosperous for those who do it properly. Stocks go down much faster than they go up and it is our right to capitalize on that. Focus on attacking aggressive and creative accounting methods these large companies use for their own benefit and covertly punish share holders, focus on the extravagent offices, private jets, wasted money, focus on cutting the huge salaries paid to executives as these companies continue to lose money.

Trying to create a more ordely market by curbing short selling is not a solution. It is a violation of our entrepreneurial rights

Analogically speaking, curbing short selling is equivalent to taking away our left hand and leaving us only with the right hand. This would be to save.... who???

Market volatility is inevitable and also a valuable tool. Share price is the effect of either responsible or irresponsible corporate actions. Allow us the right to reward or punish those companies for their good or bad decisions. You should be focused on curbing corporate actions which ultimately cause the result.

Leave us the freedom to prosper. Take care of the cause and we will handle the effect.

I'm just a little guy, whose voice probably will not even be heard, but it's worth a few minutes of my time for anyone who might be interested.

If any one has read this, thank you for your consideration.