Subject: File No. 4-590
From: Stanley Sherman

January 23, 2010

After a stock falls a given amount then shorting should only be allowed after a cumulative uptick whose volume equals or exceeds the last previous downtick. This rule will prevent a large short followed by the shorter placing a small uptick order being able to place another large short. Also, there should be no limit on normal selling by a party that owns the stock.