Subject: File No. 4-627
From: Jerry A Blair
Affiliation: retired small business owner

June 28, 2011

Any advantages of short selling adhere only to the securities industry and the successfuk short sellers. In an environment that the basis of any business is that of a "going concern", there is no reasonable claim that selling just to force the price down as opposed to selling to make a profit or timely loss is good for the individual company. Thus, in my opinion, it is not good for the industry. I maintain a margin account and a certain percentage of my investments previously included small caps and tech start up firms. Why should I have to allow my shares to be used to short against a small company that I am seeking growth. I am encouraging negative activity within my own investment.

Prior to hedge funds and the increasing involvement of international investors of great individual wealth and sovereign wealth, there might have been some true market benefits to shorting some shares in large cap stocks. However, now the positions can be so big that even large caps can be damaged. Have we already forgotten the run on the banks, mortgage companies, insurance and investment houses. In the most simple terms there you had the same industries creating a problem and then through deceit and crying to the "FED" and Treasury created a cottage "short" industry for their own benefit. The bundling of good/bad mortgages was a planned two step process for the winners of the debacle. Looking back you can see who won and who lost within the industry. The one group that was hurt the most was the individual investor and they continue to show their loss by the reduced participation in the market. You only have to look at trading volume and individual trades to see who is now responsible for the daily volume. For the most part , the trades are large and the smaller trades to a large extent are bashers for short interest, especially in micro to small caps.