Subject: Proposed amendment to Rule 15c2-11 File No. S7-5-99

Date:    4/6/99 5:04 PM
     
     
Dear Mr. Katz,
     
I am writing in opposition of the proposed amendment to Rule 15c2-11 
file no. S7-5-99.  I am the CEO of an 11 year old profitable OTC 
Bulletin Board firm, PDRx Pharmaceuticals, Inc.located in Oklahoma City,
OK.  Our shareholders would loose all of their investment in our company, 
if such a rule was adopted. Without a doubt our stock would cease to be 
offered by any reputable brokerage firm.  We are a small company with 
sales of approximately $6 million annually with 28 employees and
hundreds of small investors, all of which would be adversely affected by 
this rule change.
     
The rule seeks to put an undue burden on the market makers and traders of 
microcap stocks.  With the present restrictions to trading of OTC 
Bulletin Board stocks, this rule, if adopted, would be the final nail in 
the coffin for our firm and many others just like us. I stongly urge you 
to reconsider this amendment and spare the devastating impact that small 
companies will face if legitimate market makers are driven from these 
markets and cease to trade these securities.
     
I strongly oppose this rule change and ask you to do so as well.
     
Sincerely,
     
     
Robert Holsey, R.Ph., D.O.
CEO