Subject: File nr. S7-24-99
     
Date:    12/8/99 12:28 PM
 
 
To Jonathan G. Katz, Secretary,
 
Considering:
 
(1)  The existence of NASD rule 3370 (b)(2)(B) that allows market maker 
       firms to sell millions of non-existent shares of
       NASDAQ and OTCBB    securities. 
 
(2   The limited scope of NASD rule 3350 "The Short Rule" which is 
       supposed to prohibit the practice of "Bear Raiding "
       and "Piling On" but due the "Primary Market Maker" exemption is 
       completely negated for NASDAQ stocks. Rule 3350
       has not applicability to the OTCBB securities at all. 
 
(3)  The limited scope of the Limit Order Display Rule which does not 
       apply to OTCBB stocks.
 
Drawing the conclusion that:
 
      These conditions create an environment where legalized and 
      systemic constructive fraud flourish by Market Makers
      and  Big Firms".  One good example is Kaire Holdings (KAHI). 
 
Making an appeal on your Organisation: 
 
     To protect the interest of the investing public by changing or 
     adjusting above mentioned rules in in such a way, that the 
     systemic constructive fraud by MM'S and "Big Firms" will stop. 
 
Yours faithfully,
Roger P. Kublin