Subject: File # S7-5-99   Please Copy to:  Arthur Levitt, Chairman, I
Author:  Mike Harader <harader@hercprod.com> 
Date:    5/3/99 11:41 AM
     
     
Regarding the proposed amendments to Rule 15c2-11, HERC Products 
Incorporated, being a small cap, OTC BB traded security, opposes the 
proposed ammendments to this rule.  By passing this legislation you will 
effectively remove us from the public markets.  I am very concerned about 
the ability of our company to finance our current and future growth if the 
amendments go through.  It is my understanding that the proposed 
amendments will hinder the ability of our current market makers to publish 
a priced quotation in our security.  This will decrease liquidity and do 
irreparable harm to our stock.
     
Thank you in advance.
     
Sincerely,
     
     
     
Michael H Harader, CFO
HERC Products Incorporated
     
Please Copy to:  Arthur Levitt, Chairman, Isaac C. Hunt, Jr., Norman 
Johnson, Paul R. Carey and Laura Simone Unger.