On Sat Jul  8 19:47:54 2000,
The following information was submitted: 
Host: 154.5.109.45
submit_by = ELN/sujihoward@earthlink.net 
Name = L.James Howard
Professional_Affiliation = Investor
Subject = Short Sales (Release No. 34-42037; File No. S7-24-99)
Comments = I am in favor of proposed Concept Release (No. 34-42037; File No. 
S7-24-99).
     
INVESTMENT EQUITY: 
It is essential for companies be able to access investment capital for creation 
, development , operating expenses , acquisition to grow.
In order for this process to proceed equitably it is imperative investors 
placing funds in such companies receive protection from fraud and stock 
price/distribution manipulation. 
     
MARKET MAKERS DEFY BUSINESS & ECONOMIC LOGIC:
Small business is a critical building block for jobs and wealth in our economy. 
Market Makers have without impunity sold more shares than they own thereby 
defying accepted economic laws of supply and demand along with being able to 
ignore company financial and business plan fundamentals.
     
PRESS RELEASES IRRELEVANT: 
The purpose and practice of issuing company press releases has become irrelevant
because stock price manipulation and stock distribution control by those 
controlling the market negates the impact and intent of such releases.
This does result in declining or advancing stock prices without any genuine 
investor or momentum/concept triggers.
     
FAIR STOCK VALUATION & ACCESS TO CAPITAL REDUCED IN UNLEVEL TRADING ENVIRONMENT:
The denial of the affects of true market factors causes investors to be deprived
of fair stock valuation and a level investment trading field . 
The market capitalization of a company whose stock is being manipulated is 
properly suspect and with that comes reduced access to investment capital for 
growth. 
     
ROLE OF MARKET MAKERS (MM'S) COMPROMISED :
The MMs are intended to provide a fair market trading mechanism
When they become directly invested in a company through the practice of shorting
shares shorting, they are taking an uncontrolled vested interest in the 
share/company with a desire to ensure share price declines. 
This practice must cease. 
     
EXISTING LEGISLATION IS FLAUNTED: 
The Securities Act contains some protective language as it relates to investors.
     
     
Section 15A(b)(6) of the Securities Act states that the rules of a national 
securities association must be designed to:
a.)
Prevent fraudulent and manipulative acts and practices and to protect investors 
and the public interest
b.)
Perfect the mechanism of a free and open market. 
     
Section 15A(b)(11) requires that association rules be designed to produce fair 
and information quotations, and to prevent fictitious and misleading quotations.
     
     
In spite of the intent expressed by these two sections of the Securities Act, 
and unlike the Nasdaq, NYSE and AMEX, Market Makers are not required by the SEC 
to disclose short positions on OTCBB stocks. 
     
The MMs can short, even naked short, at will with no checks and balances on 
OTCBB stocks. 
This leaves OTCBB listed companies prey to market manipulation on a scale only 
limited by the greed and imagination of the MMs. 
The MMs may and do sell targeted companies stocks with the idea that they will 
never have to produce real shares. 
     
Their apparent goal makes no apparent sense as it forces some companies to fail 
by depriving them of working capital and discouraging investment. I believe 
billions of dollars are being stolen from investors in this manner. 
     
For the MMs, it's a wonderful business; sort of like selling insurance, but 
never having to pay claims. They get the money, but have no expense or 
expectation of delivering anything tangible in return.