Subject: File No. S7-19-07
From: RC Martin

September 13, 2007


Forgive me if I may appear naive but I fail to recognize the benefit to stockholders of the entire practice of short selling. I've heard it promoted under the guise it adds liquidity but I cannot accept that theory.

If John Long wishes to pay a value for a stock and Joe Short thinks that value is too high is it not enough that in a free market that Joe be entitled to pass on by? It strikes me as benefiting only the best informed and well coordinated PROFESSIONALS when they can sell something they neither own or borrow and do so under the guise it protects someone else from paying to much.

What ever happened to caveat emptor and who decided it was best for some evil intentioned market manipulator to decide what is good for me or not? I see time and time again firms crippled and forced to close by short sellers who destroy the stock and make it impossible for small firms to raise capital, I haven't seen a single occasion where deep pocketed Wall Street firms BENEFITED a company by destroying its stock value.

It strikes me as a license to steal from the small investor who neither has the resources or connections to participate with the favored few. While citizens toil daily to earn a living and invest in their future others are anointed guardians of the cash box and authorized to rape the masses. Is it not sufficient they enjoy the right and privilege not to purchase anything they feel is overvalued.

What next, homeowners in Virginia who feel the values in Los Angeles are too high will be given the right to sell homes they don't own? Your neighbor will be entitled to sell your BMW if he feels you paid to much for it?

The SEC is a joke masquerading as a protector. Giving others rights to destroy that which doesn't belong to them hardly protects anyone. Who are you kidding, the entire practice of shorting is designed to create wealth for Wall Street and it does so off the backs of small and often unknowing individual investors.

Seems easy enough to this layman, if Wall Street believes investors have priced shares too high, don't buy. Creating mechanisms to destroy value serve only those with destructive intent.