From: Randy Poole
Sent: July 11, 2005
To: rule-comments@sec.gov
Subject: File No. 4-500


Dear Mr. Katz,

I am writing regarding SEC File No. 4-500.

Small issuers traded on the Pink sheets and the OTCBB deserve rulemaking regarding member records of "short" positions and reportng and public dissemination of aggregate positions by security.

Why would you not 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?

We urgently need the SEC's action to prevent fraudulent acts, expose market manipulation, and promote fair principles of trade and protect investors.

Companies like Globalscape form the next generation of economic drivers. We are easily prone to market manipulation which at times threatens our very existence, and certainly has helped to destroy many promising young companies.

Thank you for your consideration,

Sincerely,