Subject: Reference file: S-07-08-09 Short sale proposal

April 14, 2009

I have been in the securities industry for 23 years. I was opposed to the abolishment of the short sale rule and I am in favor of re-implementing the rule in the same form as it was before. I believe I understand the issues and pressures that came about that was used as the basis for eliminating the rule. I feel it should be re-established in the exact same form. I recognize without going into detail the changes in the marketplace. However if the hedge funds say they do not have a problem with the rule being re-implemented than I suggest taking them at their word. I feel the SEC proposal is far too complicated. Keep it simpler. I oppose any idea of not being able to short on certain market movements. Keep it simple. Uptick on any day, any market. Period.

Thank you

Eric Rowley

Partner

William Blair & Company, LLC

Institutional Equity Sales and Trading