Subject: File No. S7-08-09
From: Peter D. Willms
Affiliation: Investment Advisor

May 5, 2009

Do rules exist which would prevent the snowballing of the following trading stategy:

Simplisitic example:
Large investor (or group of conspiring investors):

1) Short a group of bank stocks.
2) then, buy a ultra-short bank etf, which causes more selling of the underlying securities.
3) Cover positions at a profit.

Thank you for working on the abuses of short selling.

Peter Willms