Subject: File No. S7-08-09
From: Gordon Rodgers

September 16, 2009

Dear Chairman Shapiro,

On July 27th 2009, along with the institution of rules for the abolishment of naked short selling, the SEC announced a round table discussion would be held on September 30th dealing with the practice of short selling.

Since then the SEC has requested comment on the above the bid rule as form of reinstating the "Up Tick" rule for short selling.

Since, I cannot attend the round table discussion where I am sure many professors will be presenting papers in favor of naked short selling and short selling by raiders, I would like to have my opinion heard.

1. Naked short selling is still alive and happy because your rules do not yet place pressure on the US broker acting for foreign interests. Stop Canadian naked short selling.

2. Reinstate the "up tick" rule exactly as it is or flash traders will simply make .05 second bids below any point and continue to raid stocks.

Respectfully Submitted, Gordon Rodgers