Subject: File No. S7-26-08
From: W. Romain Spell

November 19, 2008

To whom it may concern:

I understand the SEC had a study that said this "Up-Tick" rule was no longer needed. I also understand that it was done during a Bull Market. Is it possible that the rule is not needed during a Bull Market, but may be needed when there is a chance of a deep recession, or possible depression?

I know you guys are much smarter than me, but it seems that anything that was put in just after the Great Depression to help prevent another would be very useful right now. I don't know maybe they knew what they were doing back then.

Anyway, could you please explain what it would hurt to re-instate the rule?

Suffering Greatly,

W Romain Spell