Subject: File No. 4-627
From: Robert Tecca
Affiliation: None

May 12, 2011

I have been trading for about 5 years now. In that time, I've done a lot of research and learned a LOT about the day to day movement of stocks in general, but specifically biotech. What I've seen is over and over and over again, the number of shares available to short could not possible even come close to accounting for the level of shorting that is happening on a given day. The level of naked shorting that is happening is astounding and it's all designed to take advantage of the "little guy".

The info available now is woefully inadequate and disproportionate, let alone the illegality of naked shorting that the seems to be allowed to happen.