From a substantive point of view, I think my comments were presented in the classes on Parts Nine and Fourteen, where the approach I would take to the Ninth Amendment was laid out fully. The two salient points with respect to the improvement of this essay draft are:

1. If the Ninth Amendment is to be something other than a magic rights-making machine, it needs to be considered in its historical context; and
2. Some sort of theory of "retained rights" needs to be presented.