Date:    06/22/2000  2:53 PM

Subject: OTC:BB Lack of Short Reporting and other problems.

Some Market Maker activity in Medizone International, Inc. (MZEI) is, in our 
opinion, blatantly criminal in action and has been so for years now. Coercion 
and market manipulation are common occurrences.  A FAIR MARKET BASED ON THE 
FUNDAMENTAL RULE OF THE LAW OF SUPPLY AND DEMAND HAS NOT, AND IS NOT, BEING 
FOLLOWED IN THIS SECURITY AT GREAT COST TO BOTH THE COMPANY AND ITS 
SHAREHOLDERS.  THE SHORT POSITION HAS GROWN SO LARGE AND IS SO UNREGULATED ON 
THE OTC:BB THAT IT IS NOW AGAINST THE FINANCIAL INTERESTS OF THE MARKET 
MAKERS TO ALLOW A FAIR MARKET.  THE VERY LACK OF REGULATION ENCOURAGES 
CRIMINAL ACTIVITY BY THE MARKET MAKERS.
     
The following is strongly encouraged:
     
1.  Extend regulation of short sales to all currently unregulated markets for 
non-exchange listed securities.
     
2.  Permit regulated short selling, subject to the monitoring, reporting and 
volume limitations discussed below.  We believe there is a place for 
legitimate short selling, provided it is not manipulative.  We believe that 
imposing the limitations now used in the NASDAQ National Market and in the 
national exchanges would be a very strong step forward to curbing abuse in 
the OTC markets.
     
3.  Require reporting and increased monitoring of short selling in the OTC 
markets.  This would include imposing a requirement that all short sales be 
instantly reported in such a way that the net long position of each account 
participating in a short sale and flags naked shorting, down tick shorting 
and other "bear raid shorting."
     
4.  Limit market maker short selling and permit short selling only to meet 
legitimate temporary intra-day needs to maintain an orderly market.
     
5.  Implement velocity and volume limits on short sales. Prohibit the 
immediate re-lending of shares for further short sales that have been loaned 
to permit a short trade. Establish volume limits for aggregate short sales 
that include time limits for open short positions, volume limits on related 
accounts, and allocation of the volume limits among short selling 
participants.
     
We urge the Commission to extend short selling regulations to non-exchange 
listed securities.  I would be happy to discuss these issues with the Staff 
and can be reached at (415) 868-0300.
     
Respectfully submitted,
     
Medizone International, Inc.
     
Edwin G. Marshall,
Chief Executive Officer
Chairman of the Board