Subject: File No. 4-500

August 28, 2005

As a concerned investor, I hereby ask that you Amend NASD Rule 3360 and require NASD brokers to maintain records of total "short" positions in all customer and prorietary 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.

Too many small companies are being hurt by these unregulated short positions for the monetary benefit of a small group of brokers who are reaping huge profits with other peoples money!! This discourages investors and makes it extremely difficult for these small, growing companies to raise capital as well as hurting the investors who are investing hard earned money.

Why should one market not have the same rules as another market?

As you well know, some of the LARGEST companies on the NASD,etc, started out on the 'pink sheets" OTC-BB and have created jobs and wealth for this great nation. However, many haven't as the "naked short sellers" have played a large, unscrupulous role of despressing the stock price when it is not warranted, and thereby made it impossible for the companies to raise the necessary capital driving them out of business which results in the loss of jobs and market capital.


Ron Durham