Date:    09/29/2000  10:43 AM

Subject: Release No. 34-42037; File No. S7-24-99)

Dear Sirs:
     
You have a serious perception problem building in how the OTCBB market is 
being run: a problem ruining investor confidence and destroying the very 
market itself through inaction on your part and lack of regulatory 
guideposts.  'Naked' shorting by professional MM's may have legitimacy when 
small cap B-plans are underfunded or too dangerous to warrant taking block 
positions with firm assets.  They have valid concerns of risk and loss of 
assets making markets--thus a need to borrow shares to maintain liquidity. 
The virtue of these lax standards carried with it a gurantee from MM's to 
maintain the market while reducing their exposure to loss.
Unfortunately, with these privileges and lack of oversight  comes the 
promise of abuse--abuse not easily detected nor countered.  Abuse not being 
monitored by your offices due to supposed 'lack of regulatory authority'. 
Abuses all to apparant to small retail investors who watch their micro-cap 
issues self-destruct on positive earnings reports, heavy 'buy' side ticker 
sales, superlative PR and high growth prospects.  Destroyed seemingly by the 
very professionals assigned over their dominion--the naked shorting MM's. 
Naked shorting stock they don't own and borrow to maintain liquidity.  Stock 
they may not even 'borrow' at all, causing exploding floats, and all 
justified in the name of maintain 'liquidity'.  Stock they cover in 
inexplicable ways, if ever--but can't be known because there is no way to 
find out.  A rigged market where the dealer controls the cards, stacks the 
deck, deals as he sees fit, raise and lowers the pot as needed, and adds 
cards whenever he needs his hand goosed.  Anybody playing in this card game 
is lost from the point of buy-in. 
Perhaps this is not the case--but I assure you the general public perception 
is not that. Read the message boards, there is a growing sense that 
investing in OTCBB securities is not simply risky--it's downright insane. 
Nobody would play in Las Vegas on a rigged machine--the volume dropoff on 
the exchange this year may be due to a growing realization by the public 
playing this particular game that it is just a pointless and very expensive 
lesson in futility.
     
We need your help--we need you involved--we need the whole process looked at 
from a 21st century perspective and not from the guilded age.  You are the 
only ones who can--or you'll see more of us leave--for good.
     
Thomas P. Luke