Subject: File No. S7-08-09
From: Paul Burton
Affiliation: Consultant, ex Registered Representative and OSJ Principle.

February 22, 2010

Bring back the entire up-tick rule. Anything less then a real up-tick rule with no exemptions for insiders and market manipulatores is a disgrace to the SEC and a waste of taxpayers time and money. It will not bring back investor confidence.

First I would like to say that this SEC has done the most to destroy the level playing field that has existed for years. Their lack of enforcement against the biggest players and their lack of internal insight is a disgrace. Mr. Madoff is a name that shows the true efficiencies of the SEC and their staff. I have worked in this industry for many years and have since left this industry because of the blantant back turning on the real issued that pretain to the publics interest. You over burden the little guys but allow the big firms to break the rules and manipulate the rules on a daily basis.

If a company has the desire to take there stock public they are required to go through a stock registration process. This process is both time consuming and expensive. Allowing Naked short selling and short sales allows individuals with no ethics to couterfiet stock that does not exist. If they actually follow the rules in place and locate stock to borrow, you are in fact doubling the amount of shares out in the market for every given registration. How can it be possible to create these shares with no regulator supervision or cost. This throws off the balance of true supply and demand. Short sales have and are being used today as a method of stock market manipulation. That is why the uptick rule was put in place so many years ago. To stop the powerful from influancing the market in a manipulative way. Isn't it funny how once the rule was put in place many stocks were destroyed from bear raids. That is the relentless selling of stock that does not exist with no buyers in sight to buy and support the stock. That is not true supply and demand, that is an artificial supply being dumped to destroy demand. Many stocks were sold with no shares to back up the sales. There are many investors in America who have shares in a stock that do not exist. When will these shares be replaced with real shares. Shares that are registered and are real. This is just wrong and should not be allowed.