Date:    06/21/2000  8:29 AM

Subject: S7-24-99

In regards to naked shorting on the OTCBB, this practice needs to be 
regulated.
In particular, it is all too simple for a single person to short tremendous 
quantities of stock in comparison to the total public float.  This problem 
is compounded when consultants obtain stock options for blocks of restricted 
stock comparable in size to the number of nonrestricted shares or investment 
bankers begin negotiating equity-derived financing.
     
I understand that "pre-selling" options and shorting a stock to manipulate 
financing are already illegal; however, it still happens and proof is 
difficult.
     
By further regulating the method (short selling) of manipulating microcap 
stocks, it no longer becomes necessary to determine if illegal price 
manipulation is occurring.
     
A case in point is OTCBB:PCBM.  The company has a 22.5M share free trading 
float and a shareholder's group has accounted for 37.5M of these.  The 
company believes that Dennis Gordon is pre-selling his 25M share option 
after requesting an S-8 registration against it.  Although the options, once 
exercized, will exceed the 5% reporting threshold, he is beleived to be 
selling these shares into the float while circumventing all reporting rules. 
The express goal of this is to lower the bid price to which his options are 
tied, effectively defrauding the company of millions of dollars in options 
strike price and defrauding other shareholders of the benefit of a fully 
reporting company.
     
Jeffrey C. Andle
Private Investor