May 11, 1999

Jonathan G. Katz


Securities Exchange Commission

Mail Stop 6-9

450 Fifth Street , N.W.

Washington, D.C. 20549

RE: File No. S7-5-99


Dear Mr. Katz:

I am writing to express my opposition to the proposed amendments to Rule 15C2-11, the rule that governs quoting of my Company’s stock on the NASD OTC Bulletin Board® and the Pink Sheets®.

I strongly believe these proposed SEC amendments would irreparably damage the microcap market and companies like mine where securities are traded in these markets. I believe we will see legitimate market makers leave these markets creating no liquidity for my Company’s stock.

I would appreciate your recognition of my concern in your decision process.

Very truly yours,

Patrick J. Mitchell




cc: Arthur Levitt

Isaac C. Hunt, Jr.

Norman Johnson

Paul R. Carey

Laura Simone Unger