Subject: File No. S7-18-07
From: Garth McIntosh

December 22, 2007

Your propsed restricted rule under 144 for non reporting companys will most certainly have a negative effect for companies to raise the nessesary capital to expand thier businesses. I understand that there are "pink sheets" companies that have not acted honestly in thier dealings with shareholders and I must assume you have had many complaints from these small shareholders. But what about the companies that have had to start on the pinks of which many have risen to go up to the OTCBB and beyond.

We all have to start somewhere, and your new restrictions will certainly have negative effects on small cap businesses and thier abilty to finance themselves. Please do not through out the baby with the bathwater.

Thank you for this opportunity to comment, Garth McIntosh , President, ICBS Ltd, ( ICBM )