Subject: File No. 4-627
From: Raymond E. Williams
Affiliation: Licensed Clinical Social Worker

May 28, 2011

There is no good reason for short sales to be any less public than long sales. Short sellers have access to real time information regarding long sales which communicates some level of interest in a given security. Long buyers and sellers are in the dark with regard to short sales until they are periodically published, that is that the information comes to us in fits and starts. Keeping short sales hidden for any length of time creates opportunities for manipulative trading practices which disproportionately affect smaller corporations in an adverse manner. Level the playing field all traders should be on equal and transparent footing.