Subject: s7-08-09

March 25, 2009

Dear Sec, Thank you for your kind response. I understand that it is not as easy as just reinstating a rule. I do believe 3 points would help. 1. Eliminate short times two funds. If you want to have short funds then let have them be one times equity with no margin. 2. Strict oversight for those who violate naked short selling/ spreading rumors for profit. 3. The people who are the biggest shorting advocates yell the up-tick rule does not matter so why have it. If it does not matter then why not reinstate it because computers can surely process this live time tick by tick. I think they are yelling because it does matter. Even though it is only a penny if you are trying to short or cover a large position it would make a huge difference to try and continuously short. The volume disparity makes up for the old spread disparity thereby discouraging unwarranted short selling for the purpose of true capital destruction at the expense of long term shareholders. One last point, during the 2001-03 tech bust new rules came out on full disclosure of media interviews. The last few years it is obvious people are talking their books again with no disclosure. I think if people are to go on TV, print they need to disclose their personal as well as company holdings. Not by dollars but just by position.(i.e. Long short etc.) Sincerely Richard Bell/ Bell Strategic Investments Inc.

From: Rich Bell
Sent: Monday, March 02, 2009
Subject: up-tick rule

I am happy to ask again why you do not address this issue. I have written and asked why the up- tick rule is not reinstated and I have gotten no explanation. I have stated my case why the shorts are killing our economy. No one at the SEC is interested. Please give me a rational reason why it is that you continue to support people who have only the demise of the market. Please tell me you are not part of this but rather you really believe it. I am pleading with you to give me a rational explanation of how this is helping our markets because I am too ignorant to understand. Sincerely Richard Bell

From: Rich Bell
Sent: Friday, February 20, 2009
Subject: Up-tick Rule

Dear Chairwomen,

I have been in contact with your office for months in regard to this. I know you know that people are shorting the market to zero on the bank stocks. You are either blind stupid or corrupt or a part of the process of redistribution of wealth and destruction of capital. If you do not immediately reinstate the up-tick rule on a global market basis we will collapse. I choose not to believe you are that stupid which only leads me to understand how utterly corrupt you are and why you let people like Maddof and Stanford get away with what they have. Great job thanks for your part in destroying our economy and more importantly our way of life. Good Job You Idiots. Sincerely Richard Bell