Subject: File No. 4-500
From: Timothy Munro Roberts
Affiliation:

May 11, 2005

Jonathan G. Katz
Secretary, Securities Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549

With a copy to:

Barbara Z. Sweeney
Senior Vice President and Corporate Secretary, NASD
1735 K Street, NW
Washington DC 20006-1500;

RE: SEC File No. 4-500

Dear John and Barb,

My name is Timothy Roberts and I am the CEO of a publicly traded OTC bulletin board company. We feel we have been the victims of naked shortening in our stock, or at least we believe we have been since there is no way to really tell what is happening with the current rules for broker dealers and market makers. I urge you to take immediate action with the proposed rule change below.

I have worked hard for my shareholders and this system is broken and is unfair to not only me, my employees but all of the public shareholders. Please help!

I believe regulators should fix the problem. Small issuers traded on the Pink Sheets and the OTCBB deserve the same transparency and regulatory oversight of short selling as those listed on Exchanges or NASDAQ.

RULE CHANGE:

Therefore, Pink Sheets has petitioned the SEC to cause the amendment of NASD Rule 3360 and require NASD broker dealers to maintain a record of total "short" positions in all customer and proprietary firm accounts in all publicly traded equity securities as well as report this information to the NASD for public dissemination of the short positions by security. The SEC's action is urgently needed to prevent fraudulent acts, expose market manipulation, promote fair principles of trade and protect investors.

Sincerely,

Timothy Munro Roberts

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