From: Kent N. Jacobson [kentj@telus.net]
Sent: Friday, March 07, 2003 10:40 AM
To: rule-comments@sec.gov
Subject: File No. SR-DTC-2003-03 Abusive short selling
Re: SEC Request for Comment on companies exiting the DTC, and abusive 
short selling.

Dear Sir or Madam,

Our company is now considering withdrawal from the DTC, as we have been 
subject to abusive, naked short selling, and must find a way to combat it.

We have complaints from interested buyers that they are unable to fill 
orders to buy, either AT the supposed offer price or even ABOVE the offer
 price, for days on end.  Market makers refuse to sell at the posted offer 
 price because there is an inappropriate interest in keeping the share 
 price low.

Whenever there is any buying volume a day-end trade of extremely low volume 
(in which the cost to execute the trade would be higher than the value of 
the trade itself) is placed to keep our closing price artificially low.  
Also, these malicious trades are entered minutes into the trading session 
each day to establish an artificially low price at the outset.  The only 
people who could afford these trades, which make no economic sense, are 
traders, or those working in collusion with them to maintain an artificially 
low share price.

After seeing the abusive trading patterns being used to attack our company, 
I must ask you to firmly reject any motion to abandon physical stock 
certificates, as these are the only way to protect ourselves against naked 
short selling.  We further feel we must withdraw from the DTC, and that this 
continue to be allowed.  DTC lends to naked short sellers a multiple factor 
against our own shares.  We feel this is unacceptable, and we must be able 
to defend ourselves.

Regards,

Kent N. Jacobson
President and CEO
James Barclay Alan Inc.
mailto:kentj@telus.net