Subject: File No. 4-627
From: John Bird

May 6, 2011

Currently there are over 100 publicly traded Chinese companies that can be described as "targets" for short sellers. At last year's peak, these companies represented over 25 Billion dollars of market capitalization. Absent a predatory and well rewarded short selling community those companies would very likely have grown. As a direct result of information made public by short sellers these companies are receiving long overdue regulatory scrutiny.

Prior to my submitting SAIC financial documents I obtained from China at my diligence and expense, you had never heard of them. Take away my profit motive and I wouldn't have bothered locating the information much less sending it to you. Numerous other investors saw the opportunity in betting against the "China Miracle" and committed vast amounts of time and money to expose these companies. How many of your investigations trace directly to those efforts?

The shareholders lost significant amounts of money as literally dozens of these constructs have been exploded as outright frauds. And as might be expected (but not understood) the shareholders blame the messenger. The problem isn't short selling, the problem is the original marketing of the company by the cadre of pimps that fully understood the swindle.

The current rules controlling short selling are onerous and problematic as a practical trading matter. Forced buy ins, limited availability of shares, extremely high interest rates, trading halts, all conspire to make the returns less attractive than they should be for the assumed risk. Hopefully you appreciate the value of bounty hunters looking under every rock for the bad guys. Don't make the process so untenable that it will drive away your best allies.

More information is always preferable to less but the goal for the information needs to be understood. Weekly short interest numbers would be great. Identifying sizeable players in 13-D will also be of great help. Imagine how easy it will be to gather a crowd if the public is alerted to Einhorn or Soros's latest short. If the goal is to reduce the impact of short selling you will be sorely disappointed. If the goal is to quiet the critics, you will also be disappointed. But if the goal is to increase the data available to all market participants, then your disclosure steps can prove to be very helpful.

John Bird