On Thu Jul  6 22:12:17 2000,
The following information was submitted: 
Host: 12.12.210.41
submit_by = diamond43@worldnet.att.net 
Name = Ray & Leslie Diamond
Professional_Affiliation = Investors
Subject = Short Sales (Release No. 34-42037; File No. S7-24-99) 
Comments = Dear Sirs:
We own many thousands of shares of stock in a company that is being severely 
manipulated by Market Makers.  This company is INVT or Invest America.  It 
recently began trading on the Frankfurt Exchange, but the German Market Makers 
cannot get any Certificates from the American Market Makers. The American Market
Makers have shorted this stock so severely that there are no certificates 
available, yet the share price is being artificially held down.
     
We are writing you this letter to show that we are in favor of the proposed 
Concept Release (No. 34-42037; File No. S7-24-99). It is known that the life 
blood of a small company is access to capital for creation and growth. It is 
also known that investors who place funds in such companies expect and deserve 
protection from fraud and manipulation. Small business is a critical building 
block for jobs and wealth in our economy. MMs have steadily been selling more 
shares than they have bought, defying the laws of supply and demand, solid 
company fundamentals and favorable company press releases, resulting in 
plummeting stock prices. The laws of supply and demand have been denied and 
investors deprived of fair value. Meanwhile, the company valuation of stock has 
been greatly reduced and with it, access to investment capital for acquisitions 
and growth. 
     
The MMs are supposed to provide a fair market trading mechanism, yet ,when they 
become invested through shorting, they actually have a vested interest in seeing
the price fall. This practice must be brought under some form of control. 
     
The Securities Act provides certain protective language as it relates to 
investors. Section 15A(b)(6) of the Securities Act says that the rules of a 
national securities association must be designed, among other things to prevent 
fraudulent and manipulative acts and practices and to protect investors and the 
public interest, and perfect the mechanism of a free and open market. Section 
15A(b)(11) requires that association rules be designed to produce fair and 
information quotations, and to prevent fictitious and misleading quotations. In 
spite of the intent expressed by these two sections of the Securities Act, and 
unlike the Nasdaq, NYSE and AMEX, MMs are not required by the SEC to disclose 
short positions on OTCBB stocks. 
     
The MMs can short, even naked short, at will with no checks and balances on 
OTCBB stocks. This leaves the OTCBB listed companies prey to market manipulation
on a scale only limited by the greed and imagination of the MMs. The MMs just 
keep selling the targeted companies stocks with the idea that they will never 
have to produce real shares. Their apparent goal is to force the company to fail
by depriving it of working capital and discouraging investment. It is my belief 
billions of dollars are being stolen from investors in this manner. For the MMs,
it's a wonderful business; sort of like selling insurance, but never having to 
pay claims. They get the money, but have no expense or expectation of delivering
anything tangible in return. This unfair and counter productive practice cannot 
go on. 
     
MMs must be held accountable by requiring mandatory disclosure of MM short 
positions on all OTCBB listed stocks. In this manner, excessive shorting can be 
made known to the investing public, monitored for excess and corrected by the 
SEC/NASD. Then and only then can investors in these stocks be treated with the 
appropriate protection against fraud and manipulation. 
     
Sincerely,
     
Ray & Leslie Diamond