Subject: File No. 4-500

September 2, 2005

I strongly support the proposal by Pink Sheets to amend NASD Rule 3360 and require NASD broker dealers to maintain a record of total short positions, customer and proprietary, in all publicly traded equity securities and to report this information to the NASD for public dissemination of the short positions by security. The SECís action on this issue is urgently required to prevent fraud and market manipulation for the protection of individual investors. Naked shorting of over-the-counter securities by certain market makers is a blatant disregard of the principles by which the markets are intended to function.

Gerald E. Patera