Subject: File No. S7-08-09
From: Dan Cordwell

June 2, 2009

Personally I am against selling something I do not own, however, 'short selling' is a valid investment tool.

Unlimited/unrestricted 'short selling' is to easily abused.

I would required that last 2 sales be in the positive direction before a 'short sale' would allowed.

I also would consider a dollar limit on the 'short sale'. The dollar limit would be based on the stock/bond price and inverse activity (higher trading volume = lower $ limit) during the trading session.