Subject: File No. S7-08-09
From: Randall G. Frakes, Mr.
Affiliation: Investor/Trader

June 24, 2009

There is a theory that if we design rules the right way, we will always be protecting someone. The question is, who are we really protecting?

The markets have always had excesses on the upside and the downside. It's actually what creates the opportunity. Fair market pricing, with buyers and sellers at any price is what the market is suppossed to be about, and the way it was designed. It makes no sense to take liquidity out of the market. The shortsell rules are just wrong, and have had no basis for the economic decisions that have created the market selloff at all. Not this time around or anytime in the past since the market was designed.

At some point, no matter what the rules are, you will get a considerable selloff, but to take liquidity out of the market is a form of manipulation in itself. Again, fair market pricing and swings is what creates opportunities for all investors. The managements of these company's need to be held accountable for decisions and run there business with ethics, by providing timely and accurate information to the investing public, and not creating illusions and pointing the finger at short sellers for there own internal problems.

Randy Frakes