Subject: File No. 4-602
From: Anthony R Danaher
Affiliation: President, Registered Investment Advisor

June 17, 2010

Regarding High frequency Trading (HFT), and the Uptick Rule

It is imperative that the U.S. markets not lose their perception of being the most fair and transparent in the world. Confidence in our markets is wavering. Below are two things that can me done to help get it back.

Computer-driven HFT does not appear to provide any public utility. On the contrary, this type of trading erodes transparency and increases the costs for U.S. investors and investors from around the world who are providing the markets with investment capital. By allowing HFT to continue, we are encouraging predatory trading tacticians to use computers to game the very investors that have traditionally been the foundation of our capital markets.

In addition, the uptick rule for short selling should be reinstated and naked short selling should be banned. Short selling without an uptick also benefits the predatory and not the investor. Naked short selling is akin to counterfeiting. The failure to enforce exisitng laws against it further erodes confidence and gives the impression that the rule of law is only selectively upheld.