Date:    12/22/1999  11:54 AM


Subject: File No. S7-24-99 
Madamns/Gentlemen:
     
Something must be done the make the OTC BB trading more equitable.
     
When "market makers" (MM's and "primary" broker-dealers) can short OTC stocks 
without owning a single share, then can actually participate in a "bear raid" on
that stock by selling on a "down tic" offer, you have a case of constructive 
fraud in the marketplace.  This MUST be changed or you as a regulatory body may 
as well give these guys a credit card to the US treasury, which would be about 
as fair as the system you now have in place.   
     
Sincerely,
     
David P. Summers
15001 Walden Road, Ste, 108
Montgomery, TX. 77356
(409) 448 2222