Date:    06/29/2000  12:28 PM

Subject: File No. S7-24-99

Jonathan G. Katz 
Secretary, Securities and Exchange Commission 
450 Fifth Street, N.W.
Washington, D.C. 20549-0609
     
To Whom it May Concern:
     
I am writing in reference to the proposed regulation of short sales of 
securities, File No. S7-24-99.  I am pleased to see that the SEC is looking 
into revising the rules, taking into account the technological improvements 
that have heightened transparency in the markets, and that you are looking to 
prevent manipulative abuses by OTC Bulletin Board stock market makers.  As an 
individual who trades his own stocks, I am very interested to see that such 
abuses are prevented.
     
I realize that no system will stop all abuses, and do not begrudge the market 
makers their profits, even those from legitimate short-selling; I am only 
concerned about the manipulative tactics I have seen whereby the market 
makers drive prices down to acquire additional shares, and look forward to 
the SEC reining in this type of abuse by requiring full disclosure of short 
selling by market makers.
     
Thank You, 
Mitchell S. Baxter
Attorney-at-Law