Subject: My comment on SECTION G, File No. S7-24-99

Date:    11/14/99 8:37 PM
     
     
     
   Dear SEC,                                                                  
            11/14/1999
     
   I fully support the new requirement of for any companies traded on the
OTCBB to file regular 10-Q and 10-K with the SEC. I believe all public 
companies have obligation to fully disclose its financials to the public. 
Shareholders are in fact owners of these public companies and they have 
rights to know public company operations.  I fully applaud the action 
taken by the SEC against the Internet Frauds committed by some insiders 
and stock promoters to take advantage of the public.  You have my sincere 
gratitude.  
   However, I believe the biggest threat to the OTC BB market order is 
outrageous stock price manipulation by some market makers and foreign 
brokerage firms.
Particularly, illegal shorting (creating shares to sell short) has been, 
in my view, the biggest fraud I have ever seen in the stock market.
When a company has only about 10 million outstanding shares, and some 
brokerage firms can sell unlimited nonexistent shares, how can market 
order be established or maintained?  If the SEC is really serious about 
protecting the public from any frauds and is willing to fight against the 
unfair practices of these big firms, the SEC should regulate short sales in 
any stock market as listed stocks.  I just desire that everyone play the game 
using the same rules.  Thank you for your time.
     
Mark K. Giannini
250 Mulberry Dr.
Glenwood, IL  60425