April 2, 1999
     
Mr. Jonathan G. Katz
SECURITIES AND EXCHANGE COMMISSION
Mail Stop 6-9
450 Fifth Street, N.W.
Washington, D.C. 20549
     
RE:  S7-5-99
     
Dear Mr. Katz:
     
This letter is to voice our opposition to the proposed amendments to 
Rule 15c2-11 which governs quoting of stock on the OTC Bulletin Board 
and the National Quotation Bureau's "Pink Sheets."
     
While we believe that the SEC is well intentioned in its efforts to 
combat microcap fraud, we also believe that these proposed amendments 
fail to recognize the impractical and onerous burden the amendment will 
place on legitimate market makers.  In fact, under these amendments, the 
responsibility of regulating and policing small company issuers, whether 
reporting or not reporting, will effectively shift from the SEC to the 
market makers who trade in these stocks.
     
Should you have any question with regard to the above, I will welcome 
hearing from you.
     
         Cordially,
     
         Devon Blaine
DB:egh
     
cc: Senator Diane Feinstein
 Senator Barbara Boxer
 Arthur Levitt, SEC Chairman
 Isaac C. Hunt, Jr., Commissioner
 Norman Johnson , Commissioner
 Paul R. Carey, Commissioner
 Laura Unger, Commissioner
 U.S. Congress Julian Dixon
 U.S. Congress Henry Waxman