Subject: File No. S7-08-09
From: Paul Carlson
Affiliation: Accountant (retired)

May 6, 2009

The uptick rule should be reinstated.

Circuit breaker rules will not stop the traders and hedge fund operators from piling onto a stock and driving it down through their concentrated efforts of implicit collusion. It will just prolong the decline. Not to say that a circuit breaker rule would not be a added help to allow the market to work without interference from market manipulators.

It is not a coincidence that the financial companies were driven down one at a time, nor is it a coincidence that the prior and working uptick rule was dropped in July 2007 at the top of the market. No, that did not cause the market decline, but it contributed to the rapid demise of some companies that may have survived if not for the short sellers.

Another reason for needing the uptick rule is that it appears the SEC cannot or will not enforce the naked short selling rules. The uptick rule would make it harder to sell stocks short and therefore reduce naked short selling in the process.

I urge you to place the prior uptick rule back on the books and actively enforce naked short selling rules.