December 7, 1999

Dear SEC

I am writing in regards to the proposed law concerning the short selling of OTCBB stocks(Proposal # S7-24-99). The naked shorting of OTCBB stocks should be eliminated. One of the main reasons why "penny" stocks are so risky and volatile is not solely because of the companies themselves, but because of the rampant naked shorting by market makers and offshore brokers. This activity goes unchecked everyday and must be dealt with accordingly.

The abolition of naked shorting in conjunction with the requirements of being fully reporting will ensure a fair and equitable market for investors and companies alike, a market where a company's true value is reflected in the price and not distorted, suppressed or inflated artificially by manipulation.


Chris M. James
CODA Development
Chief Financial Officer