Subject: File No. 4-627
From: TOM D
Affiliation: CPA

May 6, 2011

It is my firm belief that no one (individual or firm) should be allowed to short a security that they do not own. It is counter productive to the underlying "investment" theme of the markets and contributes to false rumors and market manipulation by those with no vested interest other than seeing a security/company crash. This is not in the overall social or economic interest of the country. It is nothing more than "betting against". On the other hand if one owns a stock that is subject to volatility then shorting it is a valuable investment tool/strategy in the short run, since the overall strategy, via ownership, is to have the security increase in value over the long run. It is time to return to using markets to help companies/individuals achieve financial success over the long term and NOT turn it over to short term speculators who have no interest in long term success of the company or country. If you choose to continiue to allow naked short selling then you must consider taxing the short term profits at the highest levels so that someone in addition to the individual benefits.