Date:    12/22/1999  5:07 PM


Subject: File No. S7-24-99
Subject:  Naked Shorting and MM stock price manipulation
     
I would like to applaud the proposed initiative that is being considered 
by the SEC to help alleviate some of the "theft" and "deceit" that is 
currently going on in the OTC/BB arena.  It is quite obvious that Due 
Diligence and research on companies that are listed in this trading 
arena, in many cases, is worthless because of the manipulation that is 
being conducted there.  It is quite obvious that "Naked Shorting" and 
price manipulation is totally out of control.  By investigating the 
relatively small amount of float that is available in many very good 
companies listed as BB stocks, you don't have to look very far to find 
the reason for the relatively poor stock price performance.  It is the 
manipulation that is being conducted by the MMs and people that are able 
to use "Naked Shorts" to sell non-existent shares of stock.  These same 
people then use public forums such as Yahoo, Raging Bull, and Silicon 
Investor, to spread their lies, half-truths, and any other scare tactics 
available to coax investors into selling their shares, so that they can 
earn (and I use this term loosely) money on their short sell.  I think 
that it is outrageous that these people are allowed to make money off of 
these struggling companies while continuously bashing and scaring away 
potential investors simply for their own arrogant, self centered
agenda.  Many of the potential high rising companies are being 
"punished" by these manipulators simply because they can do it for their 
own self-gratification.
     
It is my feeling that shorting stocks should not be allowed, PERIOD.  I 
realize that, because the way that markets are made now, short selling 
is needed by MMs, however I think that this practice should be changed 
so that the market is determined by the buyers and sellers.  The MMs are 
abusing their power to set stock prices by walking down prices on 100 
share buys between themselves, even when there are more MM sales than 
buys.  Unfortunately, we as individual investors are at their mercy.  I 
think that the abuse needs to stop.  Eliminating naked shorting and 
significantly reducing shorting all together would help alleviate this 
problem.  However, the long range solution to the problem would be to 
replace the existing trading arena with an arena the would bring 
potential buyers and sellers together to trade among themselves.
     
The SEC is the watchdog for the individual investors and I am glad to see 
that at least some of the out-and-out investor rip-off schemes are being 
addressed.  There are many other areas of abuse that need to be 
addressed, but you have to start somewhere, and this is one of the worst 
areas for abuse.  The next step will be to make examples out of the 
"thieves" that still insist on trying to use these tactics to steal from 
the majority of uninformed and vulnerable individual investors.
     
I'm sorry that this comment is so long, but I feel that if we individual 
investor do not take this opportunity to voice our feeling about the 
abuse and out-and-out theft that is going on in the market, then we are 
doomed to relive it time and time again.  And those companies that are 
struggling to become one of the super-companies of the future are faced 
with a slow growth pattern; being gobbled up by other companies that are 
waiting by like vultures to buy up technology for a song; or forced into 
bankruptcy because they cannot get the investors that they need to
grow.  And all this simply because they have become a target of these 
thieves with their own selfish agendas and these same people could care 
less about the company's potential or its future.
     
     
Sincerely,
     
Chuck Stelzman