Subject: File No. S7-08-09
From: Ronald B Booth
Affiliation: Accountant

May 4, 2009

The SEC must restore pre-2007 short selling rules to bring some fairness back to short selling transactions. With the use of leverage, many large fund managers and high net worth individuals can accumulate sufficient capital to make an assault on stocks, driving stocks to a level that can not be justified by fundamentals alone. In many cases brokerage firms are turning a blind eye to naked shorts allowing short transactions in excess of the ability to borrow.

That is not to say a return of the up-tic rule will stop predatory shorting but it will surely limit their ability to drive down stock prices unimpeded.

Many of us small investors simply feel out-gunned when it comes to the market.

Restore short selling rules to their pre-2007 position.