Subject: File No. S7-08-09
From: Elizabeth a Pearce, CFA

February 20, 2010

While I am sure others will be more elegant in their comments, I wanted to add my voice to those of many other professional investors who believe that naked shorting and the elimination of the "uptick rule" have contributed in a meaningful way to the volatility of the 2008 and the first ten weeks of 2009.