Subject: File No. 4-500
From: W. Richard Ulmer, President & CEO
Affiliation: InVitro International

May 2, 2005

Good afternoon;

I am W. Richard Ulmer, President & CEO of InVitro International in Irvine, California. In my opinion, there is a huge integrity issue facing the OTC stock market today which is tied to the lack of short sale position reporting & disclosure for OTC issues. Securities regulators (& shareholders) can not identify short sellers in the smaller markets; this makes it more possible for fraudulent acts to go undiscovered & manipulators to go unpunished there. I believe that we all want the integrity of OTC markets to rival that of the "bigger markets". OTC stocks should trade in an efficient, transparent, marketplace where regulations are enforced routinely as they are elsewhere. The lack of short sale information on our securities is unacceptable and we must change NASD rule 3360 as quickly as possible. I am referring to SEC File No.4-500, Request for Rulemaking Member Records of "Short" Positions & Reporting & Public Dissemination of Aggregate Positions by Security. Protecting investors and promoting principles of fair trading should be the same for OTCBB or Pink Sheet issues as for NASDAQ or those on the NYSE. Regulators have responsibilities for transparency & regulatory oversight to all investors, regardless of market size. Please make uniform rules regarding member records of "short" positions, reporting, and public dissemination of aggregate positions by security....for every publicly traded security, regardless of market size. Respectfully submitted, W. Richard Ulmer, CEO & President, IVRO


Rich Ulmer
InVitro International