Subject: File No. S7-31-08
From: Michael D Robbins
Affiliation: Retired

December 2, 2008

The SEC suffers from educated incapacity the inability to understand a simple problem because its training gets in the way. The Five Blind Mice of the SEC listened to the staff and abolished the uptick rule. This rule controlled short selling bear raids for decade after decade. You lifted it in a bull market and were astounded that the good nature of professional manipulators was nonexistent in a bear market. I was a trader on the NYSE floor for 40 years and was a Director of the Exchange. You simply donot understand the mechanics of the uptick rule.