August 15, 2005
Subject: File No. 4-500

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 enact rules changes to curb these unethical and destructive strategies.

Market transparency is vital to the health of these young companies.

Thank you

Del Rickel