Subject: File No. S7-08-09
From: Sidney W Lewis
Affiliation: Professional Engineer

May 8, 2009

I have been saving and investing for over 35 years, and now have retired. To begin, I have never understood why anyone should have the ability, approved by regulators, to sell something they do not own. There are puts and calls available, and the short selling is not investing. Short selling, even with the uptick rule, is open to conspiratorial maniplulation of stocks by as few as two persons. How are regulations of any sort going to prevent crooks from such manipulation. At least, if short selling were removed, such gambling would even up the playing field for retail investors. In the future, with more responsibility for retirement investing being placed on the individual, an unfair advantage in favor of short sellers will be even more damaging to such investing individuals. I oppose any method that allows selling assets that are not owned by the person selling same.