Subject: File No. S7-08-09
From: James A Kelly
Affiliation: Individual investor

August 20, 2009

Truth: Shorting stock allows an artificial increase in a traded companys stock float. I know of no company or long-term investor who wants their shares to be diluted for any period of time. IE. A company may agree to issue a float of 10 million shares. One big Investor/Bank or other who owns a million shares of this company creates a contract with a Short Seller(s) to loan out his million shares giving him the RIGHT to indirectly and artificially increase the float to 11 million shares by using IOUs and markers all created by the financial system. Who has the RIGHT other than the issuing company to create shares?

Investors, who believe it is their RIGHT to profit from shorting, let them use PUTS or LEAP PUTS Options while enforcing the options tax laws, and be done with Short Selling. This does not increase the float and would resolve so many problems.

Eliminate SHORT Selling, use PUTS or LEAP PUTS Options in place.