World Wide Stone Corporation
New Corporate Offices, Factory Showroom and Warehouse: 
5236 South 40TH Street, Phoenix, Arizona 85040, USA 
Telephone (602) 438-1001 <> Telefax (602) 438-6888
     
Jonathan G. Katz
Secretary, Securities and Exchange Commission 
Mail Stop 6-9
450 Fifth Street NW
Washington DC, 20549
     
re: file no. S7-5-99
     
Dear Mr. Katz
     
I am writing you to urge you not to pass the above referenced rule changes to 
15c2-11. I agree that fraud in this segment of stock trading is high and an 
enormous problem of concern to us all. However this proposed action will, in my 
opinion, seriously exacerbate the problem. No broker dealer will be able to 
accept such a liability as proposed and therefor will not be trading in pinks or
bulletin board stocks.
     
I believe the SEC is well intentioned in its efforts to combat microcap fraud, 
but fails to recognize the impractical and onerous burden this amendment would 
place on legitimate market makers. Under these amendments, the responsibility of
regulating and policing small company issuers, whether reporting or 
non-reporting, would effectively shift from the SEC to the Market Makers who 
trade in these stocks.
     
Please sir, let's not allow this serious error to pass through the system. We 
will be forced to live with the damage done for a long time. Thank you.
     
Sincerely,
     
     
     
Frank Cunningham
     
President