Subject: File No. S7-08-09
From: Aaron D Shafter
Affiliation: President, Great Mountain Capital Management LLC

May 5, 2009

Re-institute some form of the uptick rule. It was a break on volatility in my opinion. I think rule 10a-1 worked. I traded for a hedge fund after stocks went to penny increments and the system still functioned. We were still able to short but we knew we couldn't pound a stock into oblivion.

The Hong Kong stock market still has an uptick rule. That rule was instituted in 1998 after the Asian Financial crisis. Their market still functions and the trading systems are able to handle it. The claim that our systems could not is clearly false.