Subject: File No. 4-500

September 2, 2005

Dear Security and Exchange Commission:

As an individual investor, I am asking for your help in curbing naked short selling in ALL publicly traded equity securities INCLUDING PINK SHEET STOCKS. It is unfair, and should be criminal to allow deep pocket investors to use their financial muscle to manipulate stocks INCLUDING PINK SHEET STOCKS. I am seen first hand the devestation that happens to these small, start up companies when their market capitalization is reduced to nothing. It is unfair to allow market makers in PINK SHEET STOCKS to naked short sell securities that they don't own. They never have to keep any records or perform any type of reporting.

Please, I urge your help in passing the amendment of NASD Rule 3360 and require NASD broker dealers to maintain a record of total "short" positions in all customer and proprietary firm accounts in all publicly traded equity securities as well as report this information to the NASD for public dissemination of the short positions by security. The SEC's action is urgently needed to prevent fraudulent acts, expose market manipulation, promote fair principles of trade and protect investors.

There is a crisis facing the OTC market today in the lack of short sale position reporting and disclosure for OTC issues. This lack of transparency regarding short selling in the OTC market allows fraudulent acts to go undiscovered and manipulative short sellers to hide.

Please pass the SEC File No. 4-500. Request for Rulemaking Regarding Member Records of "Short" Positions and Reporting and Public Dissemination of Aggregate Positions by Security.

Thank-you for your time an consideration!


Ben Shearrow