Subject: File No. S7-19-07
From: Nick Noecker

July 25, 2008

PLEASE get moving on new short selling rules. Selling stock short (both Naked and Borrowed) is nothing more than MANIPULATION of the market. The float of the stock is artificially increased with the sole purpose of causing the share price to fall. Nothing other than MANIPULATION defines this strategy and as such should be banned along with other SCHEMES that attempt to control the market price of a Companie's shares. Should an investor actually have clear title to shares and wishes to profit from a short sale (known as "SHORTING AGAINST THE BOX") no manipulation could be charged. Uptick this or that will not prevent the manipulation of determined hedgfunds and mutual funds that attempt to manipulate share price trends (of the type that caused the RUN on Bear Stearns) for their gain.