Subject: File No. 4-500

November 3, 2005

To whom it may concern:

This letter refers to SEC File No. 4-500. Request for Rulemaking Regarding Member Records of "Short" Positions and Reporting and Public Dissemination of Aggregate Positions by Security.

OTCBB-traded companies deserve the same regulation regarding short selling as NASDAQ and AMEX listings. For smaller American companies to succeed, and for American investors to reap the benefits of the successes of up-and-coming companies traded on the Bulletin Board, there must be transparency and efficiency in the stock markets. Expose naked short selling for what it is: crass manipulation by those "in the know."

It is shameful that this e-mail even needs to be written.

James M French