Subject: Ref: File No. S7-5-99 Author: "Lin Xu" Date: 5/11/99 3:33 PM Mr. Jonathan Katz, Secretary Securities and Exchange Commission 450 5th Street, NW, Mail Stop 6-9 Washington, DC 20549 Ref: File No. S7-5-99 Dear Sir: I am writing on behalf of Avani International Group Inc. an OTC Bulletin Board Company. The proposed rule amendment to OTC stocks, will severely affect our ablity to finance our current operations, as well as future growth of the company. We strongly urge you to stop the proposed rule amendment from becoming law. Yours truly, Dr. Peter Khean President cc Commissioners Arthur Levitt, Issac Hunt Jr. Norman Johnson, Paul Carey and Laura Simone Unger