Subject: opposition to proposed rule 15c2-11 changes. File NO. S7-5-9

Date:    4/6/99 9:54 AM
     
     
To: Jonathan G. Katz, Secretary SEC
     
Subject: Opposition to proposed rule 15c2-11 changes. File NO. S7-5-99
     
     
The proposed changes to Rule 15c2-11, the rule that governs OTC Bulletin 
Board and "Pink Sheet" quotations has
just come to my attention.
     
I am extremely worried that this change will cause the legitimate market 
makers who follow our stock (OTC BB: NKCIF)
to withdraw from making a market in our securities. This would have a 
devastating effect on our ability to raise capital
for growth and would penalize our shareholders enourmously.
     
If the intent is to weed out scam artists, my concern is that the only 
people who will be weeded out are the legitimate
market makers who we absolutely depend on to make a market in our securities.
     
Accordingly, we are opposed to these changes.
     
I would also be happy to discuss this further over the phone. (781) 229 
-2924 ext 103.
     
Sincerely
     
Richard Rabins
CEO
NewKidCo International, Inc.