Subject: File No. S7-08-09
From: Walter S Wilmanski, CFA

August 18, 2009

This is my comment, Respectfully Submitted, to the Securities and Exchange Commission, regarding the various proposals on the Restriction of Short Sales.

In RE Short Sales, and Abusive Short Sales:

My suggestion is to permit Short Sales of any Security if and only if such sales are at a price equal to or greater than a Fixed Percentage above the last and best Bid.

The Fixed Percentage should be something like 25 Basis Points (1/4 of One Percent). This percentage should be fixed and should be applied to all Equity Securities.

For instance, if the Best Bid for IBM is $100.00, then Short Sales should only be permitted at a price of $100 times 1.0025. This means that a Short Sale could only happen at $100.25. This is easy to understand, and is equitable to both Listed Companies and Traders.

This would Stop the Unethical and Illegal Power Shorting that has been permitted to destroy a Fair and Level Playing Field in the Equity Securities Markets.

Please hurry and implement such a Reasonable Rule before the Power Shorts destroy the entire US Equity Securities Market. There is Nothing Wrong with strategically Shorting a Stock, but Power Shorting that happens constantly that is only designed to Destroy Prices for no reason should Immediately Be Stopped, and Stopped for once and for all.

Make the rule 25 basis points and Save the Markets. This is my idea, and it is Fair, and this will prevent Power Shorting to Zero, which could happen under present conditions.

Respectfully submitted on Monday, August 17, 2009, by Walter S. Wilmanski, CFA.