Subject: File No. 4-500
From: George A. Paxton
Affiliation:

May 3, 2005

To Whom It May Concern:

I am urging you to please correct the problem that exists in the short selling activities on the OTCBB and Pink Sheets. It seems odd that in today's regulatory environment that to have 2 sets of rules ...mostly based only on size of company..one for the larger company exchanges (NASDAQ,AMEX,NYSE) and one for small companies(OTCBB,Pink Sheets) is rather discriminatory. A simple amendment to NASD Rule 3360 may not entirely solve the problem but it will go a long way in weeding out the most blatant abusers of the system. As a shareholder of securities on both OTCBB and Pink Sheets exchanges I implore you to give the small companies a chance to thrive without having to fight unscrupulous traders, market makers and brokerage firms.

George A. Paxton