Subject: File No. S7-24-99

Date:    11/22/99 8:22 PM
     
     
Dear SEC,
     
 I'd like to first thank the SEC for the opportunity to voice my opinion
on this matter. Seeking opinions of those that have witnessed the 
negative effect of 'naked shorting' has me hopeful that you are serious 
about this problem. I have e-mailed you in the past about my suspicions 
of this and have received a reply that I thought was some sort of form 
letter style e-mail, but I now I think that maybe someone there actually 
read it.
     
 It's an intensely frustrating thing to watch a stock that you have
diligently researched before you bought, go down in price for no 
apparent reason, even though buying is still going on. After we see the 
price forced down the 'bashers' start posting negative comments about 
the company on various message boards to convince everyone to sell, you 
can almost guess to the minute when they will show up. It's obvious what 
they're doing and probably those that are selling know it too, but they 
realize the futility of holding on to a stock that they know will be 
artificially devalued by the market makers. I've seen this happen 
countless times. And every time it happens, I tell myself that was the 
last penny stock for me, only to buy into the next one. Because the 
profit potential of a company trading on the OTC exchange is 
astronomical, that's why it attracts investors. But the 'anything goes' 
tactics of the market makers are keeping and driving away a lot of 
investors. I, for one, will no longer trade on this exchange if these 
market makers are allowed to continue as is, unfettered, in the future. 
If they're not at least held to the same trading standards as NASDAQ's. 
I'm sure I won't be the only one abandoning the OTC market if you do not 
rule in favor of the investors.
     
. The penny stock market has some what of an unfavorable reputation and 
you should be commended for your eligibility rule for the companies this 
past year. We see a lot of companies that decided not to meet these 
requirements and they were delisted. It's good to see which company is 
willing to keep their investors informed and which are not. But now we 
have the other part of the bad reputation, worse than non-reporting 
companies, the unscrupulous market makers. Will  they be allowed to carry 
on as they have been and manipulate and twist the market for their own 
greedy gains? I hope not. I hope we will see the end of this in the very 
near future.
 Not meaning to sound unappreciative for the eligibility rule but if you
had asked investors last year whether they'd want the eligibilty rule or 
S7-24-99 enforced first, my guess would be  S7-24-99. And I wouldn't be 
surprised if it was unanimous.
     
     
Thank you,
     
Duane Montgomery