Subject: File No. S7-08-09
From: Jim Robbins
Affiliation: Retired - small investor

June 3, 2009

Short selling turns the stock markets into a gambling casino. It is impossible for a small investor to invest in American industry when short selling is able to conduct bear raids on a stock at any time. I believe there is no rationale for short selling. As an example, I can not short sell my neighbor's car or any other asset without owning it first. The "borrowing" of an asset and selling it without the owner's permission should always be illegal. Brokerage houses should not be able to loan out their customer's shares for shorting. Shorting a stock you own makes no sense because this is the same as just selling the stock. Naked shorting destroys markets and the SEC has been very lax in allowing this destructive behavior. I suspect that much of the naked shorting comes from offshore hedge funds that may be run by criminal organizations or even enemies of America. This allows these orgainizations to pull money out of markets and not pay Federal income tax.

Points made in favor of short selling are invalid. Short selling does not increase the market's liquidity, in fact it removes liquidity. Short selling is not necessary to control over valued stocks. The market will determine the correct value on its own. Again the car example, aren't cars priced by the market without short selling?

If an investor believes a stock is going down they can buy a put on it. Very simple to do without selling someone else's property. If short selling is allowed then maybe we should also allow people to sell bridges they don't own.
Thank you for taking my comments.