Subject: SEC FILE NO. 4-500

October 14, 2005

Dear Mr. Katz,

I am writing regarding SEC File No. 4-500. Request for rulemaking regarding member records of "short" positions and reporting and public dissemination of aggregate positions by security.

Small issuers traded on the Pink sheets and the OTCBB deserve the same transparency and regulatory oversight of short selling as those listed on Exchanges or NASDAQ.

Please amend 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, and promote fair principles of trade and protect investors.

Many companies like ours form the next generation of economic drivers of the Information Age economy. Companies are easily prone to market manipulation which at times threatens their very existence, and certainly has helped to destroy many promising young companies.

Thank you for your consideration,

Sincerely,

Michael Moyal
Shareholder