Author:  James R Pease 
Date:    03/22/2000  11:58 AM

Subject: File No. S7-31-99

Dear Sirs:
     
I am one of the "new ones" to world of investing on-line.  As one would 
expect, I am not very knowledgeable in the "behind the scenes" of Wall 
Street.  But as a relative newcomer, I would like to express my support 
of the SEC's effort to "level the playing field."  
     
I have read many of the comments by others who are far more knowledgeable 
than I.  I applaud those who are in support of public disclosure as 
opposed to selective disclosure.  (I hope those terms are appropriate) 
Also, I have read some comments of those who defend the status quo, those 
who use terms like "safe harbor", "guidance to the market", and "guidance 
to analysts."  Some of them seem to have a very narrow definition of 
"market."  Their definition seems to exclude  those who are not part of 
the "establishment" or "insider elite."  I know the importance of the 
instructional buyers and their impact on the market, but the markets are 
more than the institutions, insiders, and brokerage houses.
     
The system they are trying to defend is not illegal, but it should be. 
There is a tangible repugnance to treating some with special privilege 
and others with utter indifference if not contempt.  The thought that 
those who are not part of the establishment must rely on channelized 
information is degrading.  The premises is that the information must be 
presented in such a way that those not part of the insider elite can - 
maybe, just possibly, with some degree of difficulty - understand what is 
being presented.
     
Some of the arguments for retaining the status quo and providing 
information to the select few appear, on the surface, to be very good, 
logical, factual presentations.  Eloquent might be applicable in some 
cases.  But, they are attempting to justify a practice whose time has 
passed, regardless of its merits in bygone ages.    When the various 
defenses are analyzed in detail and reduced to their common denominator, 
the picture is not one of something tasteful or desirable.  I am 
wondering if behind the facade there might not be lurking the same 
factors that have perpetuated "status quo"  circumstances throughout the 
ages - greed, money, and power.  Maybe there is a better way to dispense 
information and maybe its time has come in this "new market."
     
Respectfully submitted,  
     
     
J. R. Pease