Subject: File No. S7-20-08
From: J Diefenbach

August 14, 2008

The SEC uptick rule, which was in place for 75 years, should be reinstated given the repeal 7-6-07 as its learned impact on naked short selling and the overall enormous volatility experienced in our financial system. FASB may want to consider pooling mergers once again and just how non-operating writeoffs have hurt EPS rates for the overall markets and multiples. Naked short sellers need to be regulated and reported as this clearly has spun out of control of the regulators. Capital markets are just that and not a venue for wild speculation which took the likes of Bear Stearns down.