Subject: File No. S7-08-09
From: David W Reasoner
Affiliation: President, The Reasoner Group

May 14, 2009

I'm writing in response to the proposed uptick rule change.
I started in the financial services industry in 1981 as a broker when the uptick rule was in place.
In todays world of computerized trading with no specialists to create an orderly market, stock manipulation is running rampid especially on the short side of the market. Couple that with the lax enforcement of "Naked Short Selling" and all you have is stock manipulation run wild.

In the early 80's stock manipulators would find thinly traded stocks, leak inside information just like today and turn the stock market into a casino rather than a capital formation exchange. It got completely out of control until individuals were arrested and new rules were created after the 87' crash to prevent it from ever happening again.

Fast forward to today where lack of enforcement of the laws and greed by the few, place long term investors holding the bag again.

The uptick rule prevented manipulators from ganging up on stocks, spreading rumors, and drive sometimes good quality
companies into peril. The uptick rule should be reinstated,
stock manipulators should be punished, and the markets should be brought back to their original purpose of capital formation with job creation.

P.S. -There is no reason why hedge funds should not be transparent and regulated. Credit default swaps and derivatives need to be monitored and accounted for differently on institutions books.