casinolive.com Corp.
c/o Ste. 404, 110 Cambie St.
Vancouver, B.C.
V6B 2M8

April 7, 1999

Mr. Jonathan G. Katz
Secretary, Securities and Exchange Commission
Mail Stop 6-9
450 Fifth Street N.W.
Washington, DC 20549


RE: File No. S7-5-99
Dear Sirs:

We are writing you to add to the comments that you will have received from countless others with respect to the 
proposed amendments to Rule 15c2-11.  Of primary concern to us is the concept of shifting responsibility and 
possible liability to the Market Makers for adjudicating on the quality of financial statements, and the oversight role 
they will be required to perform for junior companies traded on the OTC Bulletin Board and Pink Sheet.

 We are in full support of providing a forum for full and plain disclosure, on a continuing basis.  We also support the 
need for all publicly traded companies to register their securities so that equal, standardized information is available 
to all potential investors.  We also believe that investment advisors should know about the stocks they recommend. 
However, Market Makers have limits in the access to information not already available to all investors, limits in the 
professional qualifications they have to review and acts sleuths in analysis of financial information, limits in their 
higher level of awareness than the overall investment community, limits in their judgement of the differences 
between changing business conditions and cleverly masterminded fraud.  The proposed amendments to Rule 15c2-
11 appear more like asking the auctioneer to certify that the goods he is auctioning are truly as represented by the 
seller.  How can he really know that the item is a fake that the documents are forged, etc.?  Perhaps on the most 
obvious of cases, but he should really leave that up to the experts.

If the public liability portion of their responsibility becomes too onerous, Market Makers will become so wary of the 
review process that only the most solid, “blue-chip” types of companies will ever get sponsored for trading.  The 
types of startup companies that make up the majority of the OTC Bulletin Board and Pink Sheets will become 
precluded from funding opportunities due to creating too high a level of risk for the Market Makers.

Please re-think your proposed amendments, and choose to place the review responsibility where it belongs, with the 
securities regulators, the legal and audit professionals, and the investing public.  Look at other areas that provide the 
source for fraud, and make changes to those areas first and foremost. 

Sincerely,
casinolive.com Corp.

Ian D. Lambert

President