Subject: File No. 4-627
From: nico roodt
Affiliation: senior policymaker

May 28, 2011

Short selling distorts the possibilities of compamies to attract the capital to finance innovations. It is not a mirror of the management of a company. Especially with innovative companies where money is needed to develop products for a long time there will be losses caused by research expenses in the initial years. Shorting then reduces the pps, and makes financing more difficult. In some cases (naked) short selling brings a company to its knees causing huge losses for the initial share holders. This has now happened to so many companies that private people can only conclude that it is not wise to invest in starting innovative companies, as it is better to wait untill those companies have finished their products and survived the short attacks on them. Needless to say that this will almost completely stop the long term innovative companies from even being started.