Subject: File No. S7-08-09
From: Robert C. Waters, D.B.A.
Affiliation: Professor Emeritus of Engineering Management, Geo, Washington University

May 5, 2009

I urge the Commission to reestablish the "uptick rule" that was viable for 75 years. It was simple and effective. The ability of short sellers to distroy investor confidence in the fairness of the markets must be stopped. The future of capitalism is in the balance.

I would also urge the Commission to require that a short seller own stock before selling it short and to enforce the law against naked short selling and circulating false information.