Author: Darrell Carter at Internet Date: 12/13/1999 2:03 AM Subject: S7-24-99 This is to comment on the current proposal regarding rules changes for "short sales" of stock in particular as to the application of OTCBB issues. It has been my experience that he "naked shorting" techniques used by most of the Market Makers in the OTCBB allows them to generate an artificial dilution to the stocks and allows for severe manipulation of stock prices. I realize that the intention of allowing "short sales" is to increase market liquidity for those times when the stock may be in short supply and allow for a more regulated market, however the practice has been to use this ability as a means to manipulate stock prices instead of allowing for the natural supply and demand for a particular stock to dictate the trading price. Only when the abuses generated by the Market Makers in the shorting of socks is eliminated by eliminating or restricting their ability to sell short on the OTCBB securities will anything approaching a level playing field be achieved. Until then, the investor, especially the smaller investor (as has proliferated with the rise of "on line brokerages") will be at the mercy of such blatant manipulation of stock prices.