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U.S. Securities and Exchange Commission

Comments on Proposed Rule:
Short Sales

Release No. 34-42037; File No. S7-24-99


Author: jbarry@a-znet.com at Internet Date: 07/04/2000 9:45 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Rule S7-24-99 ------------------------------- Message Contents On Tue Jul 4 21:45:59 2000, The following information was submitted: Host: 209.2.143.211 submit_by = jbarry@a-znet.com Name = Jason Barry Professional_Affiliation = Investor Subject = Short Sales (Release No. 34-42037; File No. S7-24-99) Comments = I am writing you this letter to show that I am in favor of the proposed Concept Release (No. 34-42037; File No. S7-24-99). It is known that the life blood of a small company is access to capital for creation and growth. It is also known that investors who place funds in such companies expect and deserve protection from fraud and manipulation. Small business is a critical building block for jobs and wealth in our economy. MMs have steadily been selling more shares than they have bought, defying the laws of supply and demand, solid company fundamentals and favorable company press releases, resulting in plummeting stock prices. The laws of supply and demand have been denied and investors deprived of fair value. Meanwhile, the company valuation of stock has been greatly reduced and with it, access to investment capital for acquisitions and growth. The MMs are supposed to provide a fair market trading mechanism, yet ,when they become invested through shorting, they actually have a vested interest in seeing the price fall. This practice must be brought under some form of control.  The Securities Act provides certain protective language as it relates to investors. Section 15A(b)(6) of the Securities Act says that the rules of a national securities association must be designed, among other things to prevent fraudulent and manipulative acts and practices and to protect investors and the public interest, and perfect the mechanism of a free and open market. Section 15A(b)(11) requires that association rules be designed to produce fair and information quotations, and to prevent fictitious and misleading quotations. In spite of the intent expressed by these two sections of the Securities Act, and unlike the Nasdaq, NYSE and AMEX, MMs are not required by the SEC to disclose short positions on OTCBB stocks. The MMs can short, even naked short, at will with no checks and balances on OTCBB stocks. This leaves the OTCBB listed companies prey to market manipulation on a scale only limited by the greed and imagination of the MMs. The MMs just keep selling the targeted companies stocks with the idea that they will never have to produce real shares. Their apparent goal is to force the company to fail by depriving it of working capital and discouraging investment. It is my belief billions of dollars are being stolen from investors in this manner. For the MMs, it's a wonderful business; sort of like selling insurance, but never having to pay claims. They get the money, but have no expense or expectation of delivering anything tangible in return. This unfair and counter productive practice cannot go on.  MMs must be held accountable by requiring mandatory disclosure of MM short positions on all OTCBB listed stocks. In this manner, excessive shorting can be made known to the investing public, monitored for excess and corrected by the SEC/NASD. Then and only then can investors in these stocks be treated with the appropriate protection against fraud and manipulation.


Author: njspeedo@xaranda.net at Internet Date: 07/04/2000 11:08 AM Normal TO: RULE-COMMENTS at 03SEC Subject: Rule S7-24-99 ------------------------------- Message Contents On Tue Jul 4 11:08:43 2000, The following information was submitted: Host: 12.4.108.212 submit_by = njspeedo@xaranda.net Name = norman james boyce Professional_Affiliation = Investor Subject = Short Sales (Release No. 34-42037; File No. S7-24-99) Comments = I am writing you this letter to show that I am in favor of the proposed Concept Release (No. 34-42037; File No. S7-24-99). It is known that the life blood of a small company is access to capital for creation and growth. It is also known that investors who place funds in such companies expect and deserve protection from fraud and manipulation. Small business is a critical building block for jobs and wealth in our economy. MMs have steadily been selling more shares than they have bought, defying the laws of supply and demand, solid company fundamentals and favorable company press releases, resulting in plummeting stock prices. The laws of supply and demand have been denied and investors deprived of fair value. Meanwhile, the company valuation of stock has been greatly reduced and with it, access to investment capital for acquisitions and growth. The MMs are supposed to provide a fair market trading mechanism, yet ,when they become invested through shorting, they actually have a vested interest in seeing the price fall. This practice must be brought under some form of control.  The Securities Act provides certain protective language as it relates to investors. Section 15A(b)(6) of the Securities Act says that the rules of a national securities association must be designed, among other things to prevent fraudulent and manipulative acts and practices and to protect investors and the public interest, and perfect the mechanism of a free and open market. Section 15A(b)(11) requires that association rules be designed to produce fair and information quotations, and to prevent fictitious and misleading quotations. In spite of the intent expressed by these two sections of the Securities Act, and unlike the Nasdaq, NYSE and AMEX, MMs are not required by the SEC to disclose short positions on OTCBB stocks. The MMs can short, even naked short, at will with no checks and balances on OTCBB stocks. This leaves the OTCBB listed companies prey to market manipulation on a scale only limited by the greed and imagination of the MMs. The MMs just keep selling the targeted companies stocks with the idea that they will never have to produce real shares. Their apparent goal is to force the company to fail by depriving it of working capital and discouraging investment. It is my belief billions of dollars are being stolen from investors in this manner. For the MMs, it's a wonderful business; sort of like selling insurance, but never having to pay claims. They get the money, but have no expense or expectation of delivering anything tangible in return. This unfair and counter productive practice cannot go on.  MMs must be held accountable by requiring mandatory disclosure of MM short positions on all OTCBB listed stocks. In this manner, excessive shorting can be made known to the investing public, monitored for excess and corrected by the SEC/NASD. Then and only then can investors in these stocks be treated with the appropriate protection against fraud and manipulation.


Author: lani914@home.com at Internet Date: 07/04/2000 10:01 AM Normal TO: RULE-COMMENTS at 03SEC Subject: Rule S7-24-99 ------------------------------- Message Contents On Tue Jul 4 10:01:43 2000, The following information was submitted: Host: 24.4.254.44 submit_by = lani914@home.com Name = Richard Brand Professional_Affiliation = Investor Subject = Short Sales (Release No. 34-42037; File No. S7-24-99) Comments = I am writing you this letter to show that I am in favor of the proposed Concept Release (No. 34-42037; File No. S7-24-99). It is known that the life blood of a small company is access to capital for creation and growth. It is also known that investors who place funds in such companies expect and deserve protection from fraud and manipulation. Small business is a critical building block for jobs and wealth in our economy. MMs have steadily been selling more shares than they have bought, defying the laws of supply and demand, solid company fundamentals and favorable company press releases, resulting in plummeting stock prices. The laws of supply and demand have been denied and investors deprived of fair value. Meanwhile, the company valuation of stock has been greatly reduced and with it, access to investment capital for acquisitions and growth. The MMs are supposed to provide a fair market trading mechanism, yet ,when they become invested through shorting, they actually have a vested interest in seeing the price fall. This practice must be brought under some form of control.  The Securities Act provides certain protective language as it relates to investors. Section 15A(b)(6) of the Securities Act says that the rules of a national securities association must be designed, among other things to prevent fraudulent and manipulative acts and practices and to protect investors and the public interest, and perfect the mechanism of a free and open market. Section 15A(b)(11) requires that association rules be designed to produce fair and information quotations, and to prevent fictitious and misleading quotations. In spite of the intent expressed by these two sections of the Securities Act, and unlike the Nasdaq, NYSE and AMEX, MMs are not required by the SEC to disclose short positions on OTCBB stocks. The MMs can short, even naked short, at will with no checks and balances on OTCBB stocks. This leaves the OTCBB listed companies prey to market manipulation on a scale only limited by the greed and imagination of the MMs. The MMs just keep selling the targeted companies stocks with the idea that they will never have to produce real shares. Their apparent goal is to force the company to fail by depriving it of working capital and discouraging investment. It is my belief billions of dollars are being stolen from investors in this manner. For the MMs, it's a wonderful business; sort of like selling insurance, but never having to pay claims. They get the money, but have no expense or expectation of delivering anything tangible in return. This unfair and counter productive practice cannot go on.  MMs must be held accountable by requiring mandatory disclosure of MM short positions on all OTCBB listed stocks. In this manner, excessive shorting can be made known to the investing public, monitored for excess and corrected by the SEC/NASD. Then and only then can investors in these stocks be treated with the appropriate protection against fraud and manipulation.


Author: sbrock6677@aol.com at Internet Date: 07/04/2000 9:01 AM Normal TO: RULE-COMMENTS at 03SEC Subject: Rule S7-24-99 ------------------------------- Message Contents On Tue Jul 4 09:01:16 2000, The following information was submitted: Host: 216.192.34.30 submit_by = sbrock6677@aol.com Name = sam brock Professional_Affiliation = Investor Subject = Short Sales (Release No. 34-42037; File No. S7-24-99) Comments = I am writing you this letter to show that I am in favor of the proposed Concept Release (No. 34-42037; File No. S7-24-99). It is known that the life blood of a small company is access to capital for creation and growth. It is also known that investors who place funds in such companies expect and deserve protection from fraud and manipulation. Small business is a critical building block for jobs and wealth in our economy. MMs have steadily been selling more shares than they have bought, defying the laws of supply and demand, solid company fundamentals and favorable company press releases, resulting in plummeting stock prices. The laws of supply and demand have been denied and investors deprived of fair value. Meanwhile, the company valuation of stock has been greatly reduced and with it, access to investment capital for acquisitions and growth. The MMs are supposed to provide a fair market trading mechanism, yet ,when they become invested through shorting, they actually have a vested interest in seeing the price fall. This practice must be brought under some form of control.  The Securities Act provides certain protective language as it relates to investors. Section 15A(b)(6) of the Securities Act says that the rules of a national securities association must be designed, among other things to prevent fraudulent and manipulative acts and practices and to protect investors and the public interest, and perfect the mechanism of a free and open market. Section 15A(b)(11) requires that association rules be designed to produce fair and information quotations, and to prevent fictitious and misleading quotations. In spite of the intent expressed by these two sections of the Securities Act, and unlike the Nasdaq, NYSE and AMEX, MMs are not required by the SEC to disclose short positions on OTCBB stocks. The MMs can short, even naked short, at will with no checks and balances on OTCBB stocks. This leaves the OTCBB listed companies prey to market manipulation on a scale only limited by the greed and imagination of the MMs. The MMs just keep selling the targeted companies stocks with the idea that they will never have to produce real shares. Their apparent goal is to force the company to fail by depriving it of working capital and discouraging investment. It is my belief billions of dollars are being stolen from investors in this manner. For the MMs, it's a wonderful business; sort of like selling insurance, but never having to pay claims. They get the money, but have no expense or expectation of delivering anything tangible in return. This unfair and counter productive practice cannot go on.  MMs must be held accountable by requiring mandatory disclosure of MM short positions on all OTCBB listed stocks. In this manner, excessive shorting can be made known to the investing public, monitored for excess and corrected by the SEC/NASD. Then and only then can investors in these stocks be treated with the appropriate protection against fraud and manipulation.


Author: kbrown45@hotmail.com at Internet Date: 07/04/2000 6:10 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Rule S7-24-99 ------------------------------- Message Contents On Tue Jul 4 18:10:19 2000, The following information was submitted: Host: 216.203.166.231 submit_by = kbrown45@hotmail.com Name = Kevin Brown Professional_Affiliation = Investor Subject = Short Sales (Release No. 34-42037; File No. S7-24-99) Comments = I am writing you this letter to show that I am in favor of the proposed Concept Release (No. 34-42037; File No. S7-24-99). It is known that the life blood of a small company is access to capital for creation and growth. It is also known that investors who place funds in such companies expect and deserve protection from fraud and manipulation. Small business is a critical building block for jobs and wealth in our economy. MMs have steadily been selling more shares than they have bought, defying the laws of supply and demand, solid company fundamentals and favorable company press releases, resulting in plummeting stock prices. The laws of supply and demand have been denied and investors deprived of fair value. Meanwhile, the company valuation of stock has been greatly reduced and with it, access to investment capital for acquisitions and growth. The MMs are supposed to provide a fair market trading mechanism, yet ,when they become invested through shorting, they actually have a vested interest in seeing the price fall. This practice must be brought under some form of control.  The Securities Act provides certain protective language as it relates to investors. Section 15A(b)(6) of the Securities Act says that the rules of a national securities association must be designed, among other things to prevent fraudulent and manipulative acts and practices and to protect investors and the public interest, and perfect the mechanism of a free and open market. Section 15A(b)(11) requires that association rules be designed to produce fair and information quotations, and to prevent fictitious and misleading quotations. In spite of the intent expressed by these two sections of the Securities Act, and unlike the Nasdaq, NYSE and AMEX, MMs are not required by the SEC to disclose short positions on OTCBB stocks. The MMs can short, even naked short, at will with no checks and balances on OTCBB stocks. This leaves the OTCBB listed companies prey to market manipulation on a scale only limited by the greed and imagination of the MMs. The MMs just keep selling the targeted companies stocks with the idea that they will never have to produce real shares. Their apparent goal is to force the company to fail by depriving it of working capital and discouraging investment. It is my belief billions of dollars are being stolen from investors in this manner. For the MMs, it's a wonderful business; sort of like selling insurance, but never having to pay claims. They get the money, but have no expense or expectation of delivering anything tangible in return. This unfair and counter productive practice cannot go on.  MMs must be held accountable by requiring mandatory disclosure of MM short positions on all OTCBB listed stocks. In this manner, excessive shorting can be made known to the investing public, monitored for excess and corrected by the SEC/NASD. Then and only then can investors in these stocks be treated with the appropriate protection against fraud and manipulation. Kevin Brown Dallas, Texas


Author: wc2f@yahoo.com at Internet Date: 07/04/2000 1:54 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Rule S7-24-99 ------------------------------- Message Contents On Tue Jul 4 13:54:57 2000, The following information was submitted: Host: 209.191.25.41 submit_by = wc2f@yahoo.com Name = Frank Caperello Professional_Affiliation = Investor Subject = Short Sales (Release No. 34-42037; File No. S7-24-99) Comments = I am writing you this letter to show that I am in favor of the proposed Concept Release (No. 34-42037; File No. S7-24-99). It is known that the life blood of a small company is access to capital for creation and growth. It is also known that investors who place funds in such companies expect and deserve protection from fraud and manipulation. Small business is a critical building block for jobs and wealth in our economy. MMs have steadily been selling more shares than they have bought, defying the laws of supply and demand, solid company fundamentals and favorable company press releases, resulting in plummeting stock prices. The laws of supply and demand have been denied and investors deprived of fair value. Meanwhile, the company valuation of stock has been greatly reduced and with it, access to investment capital for acquisitions and growth. The MMs are supposed to provide a fair market trading mechanism, yet ,when they become invested through shorting, they actually have a vested interest in seeing the price fall. This practice must be brought under some form of control.  The Securities Act provides certain protective language as it relates to investors. Section 15A(b)(6) of the Securities Act says that the rules of a national securities association must be designed, among other things to prevent fraudulent and manipulative acts and practices and to protect investors and the public interest, and perfect the mechanism of a free and open market. Section 15A(b)(11) requires that association rules be designed to produce fair and information quotations, and to prevent fictitious and misleading quotations. In spite of the intent expressed by these two sections of the Securities Act, and unlike the Nasdaq, NYSE and AMEX, MMs are not required by the SEC to disclose short positions on OTCBB stocks. The MMs can short, even naked short, at will with no checks and balances on OTCBB stocks. This leaves the OTCBB listed companies prey to market manipulation on a scale only limited by the greed and imagination of the MMs. The MMs just keep selling the targeted companies stocks with the idea that they will never have to produce real shares. Their apparent goal is to force the company to fail by depriving it of working capital and discouraging investment. It is my belief billions of dollars are being stolen from investors in this manner. For the MMs, it's a wonderful business; sort of like selling insurance, but never having to pay claims. They get the money, but have no expense or expectation of delivering anything tangible in return. This unfair and counter productive practice cannot go on.  MMs must be held accountable by requiring mandatory disclosure of MM short positions on all OTCBB listed stocks. In this manner, excessive shorting can be made known to the investing public, monitored for excess and corrected by the SEC/NASD. Then and only then can investors in these stocks be treated with the appropriate protection against fraud and manipulation.


Author: philipcasavant@hotmail.com at Internet Date: 07/04/2000 2:39 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Rule S7-24-99 ------------------------------- Message Contents On Tue Jul 4 14:39:20 2000, The following information was submitted: Host: 24.128.48.64 submit_by = philipcasavant@hotmail.com Name = Philip A. Casavant Professional_Affiliation = Investor Subject = Short Sales (Release No. 34-42037; File No. S7-24-99) Comments = I am writing you this letter to show that I am in favor of the proposed Concept Release (No. 34-42037; File No. S7-24-99). It is known that the life blood of a small company is access to capital for creation and growth. It is also known that investors who place funds in such companies expect and deserve protection from fraud and manipulation. Small business is a critical building block for jobs and wealth in our economy. MMs have steadily been selling more shares than they have bought, defying the laws of supply and demand, solid company fundamentals and favorable company press releases, resulting in plummeting stock prices. The laws of supply and demand have been denied and investors deprived of fair value. Meanwhile, the company valuation of stock has been greatly reduced and with it, access to investment capital for acquisitions and growth. The MMs are supposed to provide a fair market trading mechanism, yet ,when they become invested through shorting, they actually have a vested interest in seeing the price fall. This practice must be brought under some form of control.  The Securities Act provides certain protective language as it relates to investors. Section 15A(b)(6) of the Securities Act says that the rules of a national securities association must be designed, among other things to prevent fraudulent and manipulative acts and practices and to protect investors and the public interest, and perfect the mechanism of a free and open market. Section 15A(b)(11) requires that association rules be designed to produce fair and information quotations, and to prevent fictitious and misleading quotations. In spite of the intent expressed by these two sections of the Securities Act, and unlike the Nasdaq, NYSE and AMEX, MMs are not required by the SEC to disclose short positions on OTCBB stocks. The MMs can short, even naked short, at will with no checks and balances on OTCBB stocks. This leaves the OTCBB listed companies prey to market manipulation on a scale only limited by the greed and imagination of the MMs. The MMs just keep selling the targeted companies stocks with the idea that they will never have to produce real shares. Their apparent goal is to force the company to fail by depriving it of working capital and discouraging investment. It is my belief billions of dollars are being stolen from investors in this manner. For the MMs, it's a wonderful business; sort of like selling insurance, but never having to pay claims. They get the money, but have no expense or expectation of delivering anything tangible in return. This unfair and counter productive practice cannot go on.  MMs must be held accountable by requiring mandatory disclosure of MM short positions on all OTCBB listed stocks. In this manner, excessive shorting can be made known to the investing public, monitored for excess and corrected by the SEC/NASD. Then and only then can investors in these stocks be treated with the appropriate protection against fraud and manipulation.


Author: cwc@merichem.com at Internet Date: 07/04/2000 2:29 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Rule S7-24-99 ------------------------------- Message Contents On Tue Jul 4 14:29:30 2000, The following information was submitted: Host: 152.163.201.49 submit_by = cwc@merichem.com Name = C.W. Coffey Professional_Affiliation = Investor Subject = Short Sales (Release No. 34-42037; File No. S7-24-99) Comments = I am writing you this letter to show that I am in favor of the proposed Concept Release (No. 34-42037; File No. S7-24-99). It is known that the life blood of a small company is access to capital for creation and growth. It is also known that investors who place funds in such companies expect and deserve protection from fraud and manipulation. Small business is a critical building block for jobs and wealth in our economy. MMs have steadily been selling more shares than they have bought, defying the laws of supply and demand, solid company fundamentals and favorable company press releases, resulting in plummeting stock prices. The laws of supply and demand have been denied and investors deprived of fair value. Meanwhile, the company valuation of stock has been greatly reduced and with it, access to investment capital for acquisitions and growth. The MMs are supposed to provide a fair market trading mechanism, yet ,when they become invested through shorting, they actually have a vested interest in seeing the price fall. This practice must be brought under some form of control.  The Securities Act provides certain protective language as it relates to investors. Section 15A(b)(6) of the Securities Act says that the rules of a national securities association must be designed, among other things to prevent fraudulent and manipulative acts and practices and to protect investors and the public interest, and perfect the mechanism of a free and open market. Section 15A(b)(11) requires that association rules be designed to produce fair and information quotations, and to prevent fictitious and misleading quotations. In spite of the intent expressed by these two sections of the Securities Act, and unlike the Nasdaq, NYSE and AMEX, MMs are not required by the SEC to disclose short positions on OTCBB stocks. The MMs can short, even naked short, at will with no checks and balances on OTCBB stocks. This leaves the OTCBB listed companies prey to market manipulation on a scale only limited by the greed and imagination of the MMs. The MMs just keep selling the targeted companies stocks with the idea that they will never have to produce real shares. Their apparent goal is to force the company to fail by depriving it of working capital and discouraging investment. It is my belief billions of dollars are being stolen from investors in this manner. For the MMs, it's a wonderful business; sort of like selling insurance, but never having to pay claims. They get the money, but have no expense or expectation of delivering anything tangible in return. This unfair and counter productive practice cannot go on.  MMs must be held accountable by requiring mandatory disclosure of MM short positions on all OTCBB listed stocks. In this manner, excessive shorting can be made known to the investing public, monitored for excess and corrected by the SEC/NASD. Then and only then can investors in these stocks be treated with the appropriate protection against fraud and manipulation.


Author: takman@home.com at Internet Date: 07/04/2000 10:23 AM Normal TO: RULE-COMMENTS at 03SEC Subject: Rule S7-24-99 ------------------------------- Message Contents On Tue Jul 4 10:23:30 2000, The following information was submitted: Host: 24.0.176.209 submit_by = takman@home.com Name = Tim Cross Professional_Affiliation = Investor Subject = Short Sales (Release No. 34-42037; File No. S7-24-99) Comments = I am writing you this letter to show that I am in favor of the proposed Concept Release (No. 34-42037; File No. S7-24-99). It is known that the life blood of a small company is access to capital for creation and growth. It is also known that investors who place funds in such companies expect and deserve protection from fraud and manipulation. Small business is a critical building block for jobs and wealth in our economy. MMs have steadily been selling more shares than they have bought, defying the laws of supply and demand, solid company fundamentals and favorable company press releases, resulting in plummeting stock prices. The laws of supply and demand have been denied and investors deprived of fair value. Meanwhile, the company valuation of stock has been greatly reduced and with it, access to investment capital for acquisitions and growth. The MMs are supposed to provide a fair market trading mechanism, yet ,when they become invested through shorting, they actually have a vested interest in seeing the price fall. This practice must be brought under some form of control.  The Securities Act provides certain protective language as it relates to investors. Section 15A(b)(6) of the Securities Act says that the rules of a national securities association must be designed, among other things to prevent fraudulent and manipulative acts and practices and to protect investors and the public interest, and perfect the mechanism of a free and open market. Section 15A(b)(11) requires that association rules be designed to produce fair and information quotations, and to prevent fictitious and misleading quotations. In spite of the intent expressed by these two sections of the Securities Act, and unlike the Nasdaq, NYSE and AMEX, MMs are not required by the SEC to disclose short positions on OTCBB stocks. The MMs can short, even naked short, at will with no checks and balances on OTCBB stocks. This leaves the OTCBB listed companies prey to market manipulation on a scale only limited by the greed and imagination of the MMs. The MMs just keep selling the targeted companies stocks with the idea that they will never have to produce real shares. Their apparent goal is to force the company to fail by depriving it of working capital and discouraging investment. It is my belief billions of dollars are being stolen from investors in this manner. For the MMs, it's a wonderful business; sort of like selling insurance, but never having to pay claims. They get the money, but have no expense or expectation of delivering anything tangible in return. This unfair and counter productive practice cannot go on.  MMs must be held accountable by requiring mandatory disclosure of MM short positions on all OTCBB listed stocks. In this manner, excessive shorting can be made known to the investing public, monitored for excess and corrected by the SEC/NASD. Then and only then can investors in these stocks be treated with the appropriate protection against fraud and manipulation.


Author: omoucluap@aol.com at Internet Date: 07/04/2000 1:28 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Rule S7-24-99 ------------------------------- Message Contents On Tue Jul 4 13:28:00 2000, The following information was submitted: Host: 152.163.206.211 submit_by = omoucluap@aol.com Name = Paul Cuomo Professional_Affiliation = Investor Subject = Short Sales (Release No. 34-42037; File No. S7-24-99) Comments = I am writing you this letter to show that I am in favor of the proposed Concept Release (No. 34-42037; File No. S7-24-99). It is known that the life blood of a small company is access to capital for creation and growth. It is also known that investors who place funds in such companies expect and deserve protection from fraud and manipulation. Small business is a critical building block for jobs and wealth in our economy. MMs have steadily been selling more shares than they have bought, defying the laws of supply and demand, solid company fundamentals and favorable company press releases, resulting in plummeting stock prices. The laws of supply and demand have been denied and investors deprived of fair value. Meanwhile, the company valuation of stock has been greatly reduced and with it, access to investment capital for acquisitions and growth. The MMs are supposed to provide a fair market trading mechanism, yet ,when they become invested through shorting, they actually have a vested interest in seeing the price fall. This practice must be brought under some form of control.  The Securities Act provides certain protective language as it relates to investors. Section 15A(b)(6) of the Securities Act says that the rules of a national securities association must be designed, among other things to prevent fraudulent and manipulative acts and practices and to protect investors and the public interest, and perfect the mechanism of a free and open market. Section 15A(b)(11) requires that association rules be designed to produce fair and information quotations, and to prevent fictitious and misleading quotations. In spite of the intent expressed by these two sections of the Securities Act, and unlike the Nasdaq, NYSE and AMEX, MMs are not required by the SEC to disclose short positions on OTCBB stocks. The MMs can short, even naked short, at will with no checks and balances on OTCBB stocks. This leaves the OTCBB listed companies prey to market manipulation on a scale only limited by the greed and imagination of the MMs. The MMs just keep selling the targeted companies stocks with the idea that they will never have to produce real shares. Their apparent goal is to force the company to fail by depriving it of working capital and discouraging investment. It is my belief billions of dollars are being stolen from investors in this manner. For the MMs, it's a wonderful business; sort of like selling insurance, but never having to pay claims. They get the money, but have no expense or expectation of delivering anything tangible in return. This unfair and counter productive practice cannot go on.  MMs must be held accountable by requiring mandatory disclosure of MM short positions on all OTCBB listed stocks. In this manner, excessive shorting can be made known to the investing public, monitored for excess and corrected by the SEC/NASD. Then and only then can investors in these stocks be treated with the appropriate protection against fraud and manipulation.


Author: RobertxLee@aol.com at Internet Date: 07/05/2000 7:13 AM Normal TO: RULE-COMMENTS at 03SEC Subject: Rule S7-24-99 ------------------------------- Message Contents On Wed Jul 5 07:13:06 2000, The following information was submitted: Host: 172.164.19.65 submit_by = RobertxLee@aol.com Name = Robert L. Dill Professional_Affiliation = Investor Subject = Short Sales (Release No. 34-42037; File No. S7-24-99) Comments = I am writing you this letter to show that I am in favor of the proposed Concept Release (No. 34-42037; File No. S7-24-99). It is known that the life blood of a small company is access to capital for creation and growth. It is also known that investors who place funds in such companies expect and deserve protection from fraud and manipulation. Small business is a critical building block for jobs and wealth in our economy. MMs have steadily been selling more shares than they have bought, defying the laws of supply and demand, solid company fundamentals and favorable company press releases, resulting in plummeting stock prices. The laws of supply and demand have been denied and investors deprived of fair value. Meanwhile, the company valuation of stock has been greatly reduced and with it, access to investment capital for acquisitions and growth. The MMs are supposed to provide a fair market trading mechanism, yet ,when they become invested through shorting, they actually have a vested interest in seeing the price fall. This practice must be brought under some form of control.  The Securities Act provides certain protective language as it relates to investors. Section 15A(b)(6) of the Securities Act says that the rules of a national securities association must be designed, among other things to prevent fraudulent and manipulative acts and practices and to protect investors and the public interest, and perfect the mechanism of a free and open market. Section 15A(b)(11) requires that association rules be designed to produce fair and information quotations, and to prevent fictitious and misleading quotations. In spite of the intent expressed by these two sections of the Securities Act, and unlike the Nasdaq, NYSE and AMEX, MMs are not required by the SEC to disclose short positions on OTCBB stocks. The MMs can short, even naked short, at will with no checks and balances on OTCBB stocks. This leaves the OTCBB listed companies prey to market manipulation on a scale only limited by the greed and imagination of the MMs. The MMs just keep selling the targeted companies stocks with the idea that they will never have to produce real shares. Their apparent goal is to force the company to fail by depriving it of working capital and discouraging investment. It is my belief billions of dollars are being stolen from investors in this manner. For the MMs, it's a wonderful business; sort of like selling insurance, but never having to pay claims. They get the money, but have no expense or expectation of delivering anything tangible in return. This unfair and counter productive practice cannot go on.  MMs must be held accountable by requiring mandatory disclosure of MM short positions on all OTCBB listed stocks. In this manner, excessive shorting can be made known to the investing public, monitored for excess and corrected by the SEC/NASD. Then and only then can investors in these stocks be treated with the appropriate protection against fraud and manipulation.


Author: ldouds00@home.com at Internet Date: 07/05/2000 9:43 AM Normal TO: RULE-COMMENTS at 03SEC Subject: Rule S7-24-99 ------------------------------- Message Contents On Wed Jul 5 09:43:18 2000, The following information was submitted: Host: 24.4.252.4 submit_by = ldouds00@home.com Name = Lee Douds Professional_Affiliation = Investor Subject = Short Sales (Release No. 34-42037; File No. S7-24-99) Comments = I am writing you this letter to show that I am in favor of the proposed Concept Release (No. 34-42037; File No. S7-24-99). It is known that the life blood of a small company is access to capital for creation and growth. It is also known that investors who place funds in such companies expect and deserve protection from fraud and manipulation. Small business is a critical building block for jobs and wealth in our economy. MMs have steadily been selling more shares than they have bought, defying the laws of supply and demand, solid company fundamentals and favorable company press releases, resulting in plummeting stock prices. The laws of supply and demand have been denied and investors deprived of fair value. Meanwhile, the company valuation of stock has been greatly reduced and with it, access to investment capital for acquisitions and growth. The MMs are supposed to provide a fair market trading mechanism, yet ,when they become invested through shorting, they actually have a vested interest in seeing the price fall. This practice must be brought under some form of control.  The Securities Act provides certain protective language as it relates to investors. Section 15A(b)(6) of the Securities Act says that the rules of a national securities association must be designed, among other things to prevent fraudulent and manipulative acts and practices and to protect investors and the public interest, and perfect the mechanism of a free and open market. Section 15A(b)(11) requires that association rules be designed to produce fair and information quotations, and to prevent fictitious and misleading quotations. In spite of the intent expressed by these two sections of the Securities Act, and unlike the Nasdaq, NYSE and AMEX, MMs are not required by the SEC to disclose short positions on OTCBB stocks. The MMs can short, even naked short, at will with no checks and balances on OTCBB stocks. This leaves the OTCBB listed companies prey to market manipulation on a scale only limited by the greed and imagination of the MMs. The MMs just keep selling the targeted companies stocks with the idea that they will never have to produce real shares. Their apparent goal is to force the company to fail by depriving it of working capital and discouraging investment. It is my belief billions of dollars are being stolen from investors in this manner. For the MMs, it's a wonderful business; sort of like selling insurance, but never having to pay claims. They get the money, but have no expense or expectation of delivering anything tangible in return. This unfair and counter productive practice cannot go on.  MMs must be held accountable by requiring mandatory disclosure of MM short positions on all OTCBB listed stocks. In this manner, excessive shorting can be made known to the investing public, monitored for excess and corrected by the SEC/NASD. Then and only then can investors in these stocks be treated with the appropriate protection against fraud and manipulation.


Author: uf@ullrich-fischer.com at Internet Date: 07/05/2000 9:26 AM Normal TO: RULE-COMMENTS at 03SEC Subject: Rule S7-24-99 ------------------------------- Message Contents On Wed Jul 5 09:26:23 2000, The following information was submitted: Host: 216.232.114.201 submit_by = uf@ullrich-fischer.com Name = Ullrich Fischer Professional_Affiliation = Investor Subject = Short Sales (Release No. 34-42037; File No. S7-24-99) Comments = I am writing you this letter to show that I am in favor of the proposed Concept Release (No. 34-42037; File No. S7-24-99). It is known that the life blood of a small company is access to capital for creation and growth. It is also known that investors who place funds in such companies expect and deserve protection from fraud and manipulation. Small business is a critical building block for jobs and wealth in our economy. MMs have steadily been selling more shares than they have bought, defying the laws of supply and demand, solid company fundamentals and favorable company press releases, resulting in plummeting stock prices. The laws of supply and demand have been denied and investors deprived of fair value. Meanwhile, the company valuation of stock has been greatly reduced and with it, access to investment capital for acquisitions and growth. The MMs are supposed to provide a fair market trading mechanism, yet ,when they become invested through shorting, they actually have a vested interest in seeing the price fall. This practice must be brought under some form of control.  The Securities Act provides certain protective language as it relates to investors. Section 15A(b)(6) of the Securities Act says that the rules of a national securities association must be designed, among other things to prevent fraudulent and manipulative acts and practices and to protect investors and the public interest, and perfect the mechanism of a free and open market. Section 15A(b)(11) requires that association rules be designed to produce fair and information quotations, and to prevent fictitious and misleading quotations. In spite of the intent expressed by these two sections of the Securities Act, and unlike the Nasdaq, NYSE and AMEX, MMs are not required by the SEC to disclose short positions on OTCBB stocks. The MMs can short, even naked short, at will with no checks and balances on OTCBB stocks. This leaves the OTCBB listed companies prey to market manipulation on a scale only limited by the greed and imagination of the MMs. The MMs just keep selling the targeted companies stocks with the idea that they will never have to produce real shares. Their apparent goal is to force the company to fail by depriving it of working capital and discouraging investment. It is my belief billions of dollars are being stolen from investors in this manner. For the MMs, it's a wonderful business; sort of like selling insurance, but never having to pay claims. They get the money, but have no expense or expectation of delivering anything tangible in return. This unfair and counter productive practice cannot go on.  MMs must be held accountable by requiring mandatory disclosure of MM short positions on all OTCBB listed stocks. In this manner, excessive shorting can be made known to the investing public, monitored for excess and corrected by the SEC/NASD. Then and only then can investors in these stocks be treated with the appropriate protection against fraud and manipulation.


Author: haygar@zdnetmail.com at Internet Date: 07/05/2000 8:37 AM Normal TO: RULE-COMMENTS at 03SEC Subject: Rule S7-24-99 ------------------------------- Message Contents On Wed Jul 5 08:37:09 2000, The following information was submitted: Host: 24.216.25.15 submit_by = haygar@zdnetmail.com Name = Heywood Lee Garth Professional_Affiliation = Investor Subject = Short Sales (Release No. 34-42037; File No. S7-24-99) Comments = I am writing you this letter to show that I am in favor of the proposed Concept Release (No. 34-42037; File No. S7-24-99). It is known that the life blood of a small company is access to capital for creation and growth. It is also known that investors who place funds in such companies expect and deserve protection from fraud and manipulation. Small business is a critical building block for jobs and wealth in our economy. MMs have steadily been selling more shares than they have bought, defying the laws of supply and demand, solid company fundamentals and favorable company press releases, resulting in plummeting stock prices. The laws of supply and demand have been denied and investors deprived of fair value. Meanwhile, the company valuation of stock has been greatly reduced and with it, access to investment capital for acquisitions and growth. The MMs are supposed to provide a fair market trading mechanism, yet ,when they become invested through shorting, they actually have a vested interest in seeing the price fall. This practice must be brought under some form of control.  The Securities Act provides certain protective language as it relates to investors. Section 15A(b)(6) of the Securities Act says that the rules of a national securities association must be designed, among other things to prevent fraudulent and manipulative acts and practices and to protect investors and the public interest, and perfect the mechanism of a free and open market. Section 15A(b)(11) requires that association rules be designed to produce fair and information quotations, and to prevent fictitious and misleading quotations. In spite of the intent expressed by these two sections of the Securities Act, and unlike the Nasdaq, NYSE and AMEX, MMs are not required by the SEC to disclose short positions on OTCBB stocks. The MMs can short, even naked short, at will with no checks and balances on OTCBB stocks. This leaves the OTCBB listed companies prey to market manipulation on a scale only limited by the greed and imagination of the MMs. The MMs just keep selling the targeted companies stocks with the idea that they will never have to produce real shares. Their apparent goal is to force the company to fail by depriving it of working capital and discouraging investment. It is my belief billions of dollars are being stolen from investors in this manner. For the MMs, it's a wonderful business; sort of like selling insurance, but never having to pay claims. They get the money, but have no expense or expectation of delivering anything tangible in return. This unfair and counter productive practice cannot go on.  MMs must be held accountable by requiring mandatory disclosure of MM short positions on all OTCBB listed stocks. In this manner, excessive shorting can be made known to the investing public, monitored for excess and corrected by the SEC/NASD. Then and only then can investors in these stocks be treated with the appropriate protection against fraud and manipulation.


Author: beacon@telicity.com at Internet Date: 07/04/2000 2:07 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Rule S7-24-99 ------------------------------- Message Contents On Tue Jul 4 14:07:04 2000, The following information was submitted: Host: 216.227.41.37 submit_by = beacon@telicity.com Name = Kerry Goodson Professional_Affiliation = Investor Subject = Short Sales (Release No. 34-42037; File No. S7-24-99) Comments = I am writing you this letter to show that I am in favor of the proposed Concept Release (No. 34-42037; File No. S7-24-99). It is known that the life blood of a small company is access to capital for creation and growth. It is also known that investors who place funds in such companies expect and deserve protection from fraud and manipulation. Small business is a critical building block for jobs and wealth in our economy. MMs have steadily been selling more shares than they have bought, defying the laws of supply and demand, solid company fundamentals and favorable company press releases, resulting in plummeting stock prices. The laws of supply and demand have been denied and investors deprived of fair value. Meanwhile, the company valuation of stock has been greatly reduced and with it, access to investment capital for acquisitions and growth. The MMs are supposed to provide a fair market trading mechanism, yet ,when they become invested through shorting, they actually have a vested interest in seeing the price fall. This practice must be brought under some form of control.  The Securities Act provides certain protective language as it relates to investors. Section 15A(b)(6) of the Securities Act says that the rules of a national securities association must be designed, among other things to prevent fraudulent and manipulative acts and practices and to protect investors and the public interest, and perfect the mechanism of a free and open market. Section 15A(b)(11) requires that association rules be designed to produce fair and information quotations, and to prevent fictitious and misleading quotations. In spite of the intent expressed by these two sections of the Securities Act, and unlike the Nasdaq, NYSE and AMEX, MMs are not required by the SEC to disclose short positions on OTCBB stocks. The MMs can short, even naked short, at will with no checks and balances on OTCBB stocks. This leaves the OTCBB listed companies prey to market manipulation on a scale only limited by the greed and imagination of the MMs. The MMs just keep selling the targeted companies stocks with the idea that they will never have to produce real shares. Their apparent goal is to force the company to fail by depriving it of working capital and discouraging investment. It is my belief billions of dollars are being stolen from investors in this manner. For the MMs, it's a wonderful business; sort of like selling insurance, but never having to pay claims. They get the money, but have no expense or expectation of delivering anything tangible in return. This unfair and counter productive practice cannot go on.  MMs must be held accountable by requiring mandatory disclosure of MM short positions on all OTCBB listed stocks. In this manner, excessive shorting can be made known to the investing public, monitored for excess and corrected by the SEC/NASD. Then and only then can investors in these stocks be treated with the appropriate protection against fraud and manipulation.


Author: Wgraham564@aol.com at Internet Date: 07/04/2000 1:47 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Rule S7-24-99 ------------------------------- Message Contents On Tue Jul 4 13:47:22 2000, The following information was submitted: Host: 205.188.193.56 submit_by = Wgraham564@aol.com Name = Walter E Graham Professional_Affiliation = Investor Subject = Short Sales (Release No. 34-42037; File No. S7-24-99) Comments = I am writing you this letter to show that I am in favor of the proposed Concept Release (No. 34-42037; File No. S7-24-99). It is known that the life blood of a small company is access to capital for creation and growth. It is also known that investors who place funds in such companies expect and deserve protection from fraud and manipulation. Small business is a critical building block for jobs and wealth in our economy. MMs have steadily been selling more shares than they have bought, defying the laws of supply and demand, solid company fundamentals and favorable company press releases, resulting in plummeting stock prices. The laws of supply and demand have been denied and investors deprived of fair value. Meanwhile, the company valuation of stock has been greatly reduced and with it, access to investment capital for acquisitions and growth. The MMs are supposed to provide a fair market trading mechanism, yet ,when they become invested through shorting, they actually have a vested interest in seeing the price fall. This practice must be brought under some form of control.  The Securities Act provides certain protective language as it relates to investors. Section 15A(b)(6) of the Securities Act says that the rules of a national securities association must be designed, among other things to prevent fraudulent and manipulative acts and practices and to protect investors and the public interest, and perfect the mechanism of a free and open market. Section 15A(b)(11) requires that association rules be designed to produce fair and information quotations, and to prevent fictitious and misleading quotations. In spite of the intent expressed by these two sections of the Securities Act, and unlike the Nasdaq, NYSE and AMEX, MMs are not required by the SEC to disclose short positions on OTCBB stocks. The MMs can short, even naked short, at will with no checks and balances on OTCBB stocks. This leaves the OTCBB listed companies prey to market manipulation on a scale only limited by the greed and imagination of the MMs. The MMs just keep selling the targeted companies stocks with the idea that they will never have to produce real shares. Their apparent goal is to force the company to fail by depriving it of working capital and discouraging investment. It is my belief billions of dollars are being stolen from investors in this manner. For the MMs, it's a wonderful business; sort of like selling insurance, but never having to pay claims. They get the money, but have no expense or expectation of delivering anything tangible in return. This unfair and counter productive practice cannot go on.  MMs must be held accountable by requiring mandatory disclosure of MM short positions on all OTCBB listed stocks. In this manner, excessive shorting can be made known to the investing public, monitored for excess and corrected by the SEC/NASD. Then and only then can investors in these stocks be treated with the appropriate protection against fraud and manipulation.


Author: rusgus@netsync.net at Internet Date: 07/04/2000 8:11 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Rule S7-24-99 ------------------------------- Message Contents On Tue Jul 4 20:11:33 2000, The following information was submitted: Host: 206.159.156.163 submit_by = rusgus@netsync.net Name = Russell Gustin Professional_Affiliation = Investor Subject = Short Sales (Release No. 34-42037; File No. S7-24-99) Comments = I am writing you this letter to show that I am in favor of the proposed Concept Release (No. 34-42037; File No. S7-24-99). It is known that the life blood of a small company is access to capital for creation and growth. It is also known that investors who place funds in such companies expect and deserve protection from fraud and manipulation. Small business is a critical building block for jobs and wealth in our economy. MMs have steadily been selling more shares than they have bought, defying the laws of supply and demand, solid company fundamentals and favorable company press releases, resulting in plummeting stock prices. The laws of supply and demand have been denied and investors deprived of fair value. Meanwhile, the company valuation of stock has been greatly reduced and with it, access to investment capital for acquisitions and growth. The MMs are supposed to provide a fair market trading mechanism, yet ,when they become invested through shorting, they actually have a vested interest in seeing the price fall. This practice must be brought under some form of control.  The Securities Act provides certain protective language as it relates to investors. Section 15A(b)(6) of the Securities Act says that the rules of a national securities association must be designed, among other things to prevent fraudulent and manipulative acts and practices and to protect investors and the public interest, and perfect the mechanism of a free and open market. Section 15A(b)(11) requires that association rules be designed to produce fair and information quotations, and to prevent fictitious and misleading quotations. In spite of the intent expressed by these two sections of the Securities Act, and unlike the Nasdaq, NYSE and AMEX, MMs are not required by the SEC to disclose short positions on OTCBB stocks. The MMs can short, even naked short, at will with no checks and balances on OTCBB stocks. This leaves the OTCBB listed companies prey to market manipulation on a scale only limited by the greed and imagination of the MMs. The MMs just keep selling the targeted companies stocks with the idea that they will never have to produce real shares. Their apparent goal is to force the company to fail by depriving it of working capital and discouraging investment. It is my belief billions of dollars are being stolen from investors in this manner. For the MMs, it's a wonderful business; sort of like selling insurance, but never having to pay claims. They get the money, but have no expense or expectation of delivering anything tangible in return. This unfair and counter productive practice cannot go on.  MMs must be held accountable by requiring mandatory disclosure of MM short positions on all OTCBB listed stocks. In this manner, excessive shorting can be made known to the investing public, monitored for excess and corrected by the SEC/NASD. Then and only then can investors in these stocks be treated with the appropriate protection against fraud and manipulation.


Author: slhammock@mindspring.com at Internet Date: 07/05/2000 10:26 AM Normal TO: RULE-COMMENTS at 03SEC Subject: Rule S7-24-99 ------------------------------- Message Contents On Wed Jul 5 10:26:49 2000, The following information was submitted: Host: 209.86.85.122 submit_by = slhammock@mindspring.com Name = Stephen Hammock Professional_Affiliation = Investor Subject = Short Sales (Release No. 34-42037; File No. S7-24-99) Comments = I am writing you this letter to show that I am in favor of the proposed Concept Release (No. 34-42037; File No. S7-24-99). It is known that the life blood of a small company is access to capital for creation and growth. It is also known that investors who place funds in such companies expect and deserve protection from fraud and manipulation. Small business is a critical building block for jobs and wealth in our economy. MMs have steadily been selling more shares than they have bought, defying the laws of supply and demand, solid company fundamentals and favorable company press releases, resulting in plummeting stock prices. The laws of supply and demand have been denied and investors deprived of fair value. Meanwhile, the company valuation of stock has been greatly reduced and with it, access to investment capital for acquisitions and growth. The MMs are supposed to provide a fair market trading mechanism, yet ,when they become invested through shorting, they actually have a vested interest in seeing the price fall. This practice must be brought under some form of control.  The Securities Act provides certain protective language as it relates to investors. Section 15A(b)(6) of the Securities Act says that the rules of a national securities association must be designed, among other things to prevent fraudulent and manipulative acts and practices and to protect investors and the public interest, and perfect the mechanism of a free and open market. Section 15A(b)(11) requires that association rules be designed to produce fair and information quotations, and to prevent fictitious and misleading quotations. In spite of the intent expressed by these two sections of the Securities Act, and unlike the Nasdaq, NYSE and AMEX, MMs are not required by the SEC to disclose short positions on OTCBB stocks. The MMs can short, even naked short, at will with no checks and balances on OTCBB stocks. This leaves the OTCBB listed companies prey to market manipulation on a scale only limited by the greed and imagination of the MMs. The MMs just keep selling the targeted companies stocks with the idea that they will never have to produce real shares. Their apparent goal is to force the company to fail by depriving it of working capital and discouraging investment. It is my belief billions of dollars are being stolen from investors in this manner. For the MMs, it's a wonderful business; sort of like selling insurance, but never having to pay claims. They get the money, but have no expense or expectation of delivering anything tangible in return. This unfair and counter productive practice cannot go on.  MMs must be held accountable by requiring mandatory disclosure of MM short positions on all OTCBB listed stocks. In this manner, excessive shorting can be made known to the investing public, monitored for excess and corrected by the SEC/NASD. Then and only then can investors in these stocks be treated with the appropriate protection against fraud and manipulation.


Author: dholohan@home.com at Internet Date: 07/05/2000 1:48 AM Normal TO: RULE-COMMENTS at 03SEC Subject: Rule S7-24-99 ------------------------------- Message Contents On Wed Jul 5 01:48:50 2000, The following information was submitted: Host: 24.4.252.72 submit_by = dholohan@home.com Name = Daniel Holohan Professional_Affiliation = Investor Subject = Short Sales (Release No. 34-42037; File No. S7-24-99) Comments = I am writing you this letter to show that I am in favor of the proposed Concept Release (No. 34-42037; File No. S7-24-99). It is known that the life blood of a small company is access to capital for creation and growth. It is also known that investors who place funds in such companies expect and deserve protection from fraud and manipulation. Small business is a critical building block for jobs and wealth in our economy. MMs have steadily been selling more shares than they have bought, defying the laws of supply and demand, solid company fundamentals and favorable company press releases, resulting in plummeting stock prices. The laws of supply and demand have been denied and investors deprived of fair value. Meanwhile, the company valuation of stock has been greatly reduced and with it, access to investment capital for acquisitions and growth. The MMs are supposed to provide a fair market trading mechanism, yet ,when they become invested through shorting, they actually have a vested interest in seeing the price fall. This practice must be brought under some form of control.  The Securities Act provides certain protective language as it relates to investors. Section 15A(b)(6) of the Securities Act says that the rules of a national securities association must be designed, among other things to prevent fraudulent and manipulative acts and practices and to protect investors and the public interest, and perfect the mechanism of a free and open market. Section 15A(b)(11) requires that association rules be designed to produce fair and information quotations, and to prevent fictitious and misleading quotations. In spite of the intent expressed by these two sections of the Securities Act, and unlike the Nasdaq, NYSE and AMEX, MMs are not required by the SEC to disclose short positions on OTCBB stocks. The MMs can short, even naked short, at will with no checks and balances on OTCBB stocks. This leaves the OTCBB listed companies prey to market manipulation on a scale only limited by the greed and imagination of the MMs. The MMs just keep selling the targeted companies stocks with the idea that they will never have to produce real shares. Their apparent goal is to force the company to fail by depriving it of working capital and discouraging investment. It is my belief billions of dollars are being stolen from investors in this manner. For the MMs, it's a wonderful business; sort of like selling insurance, but never having to pay claims. They get the money, but have no expense or expectation of delivering anything tangible in return. This unfair and counter productive practice cannot go on.  MMs must be held accountable by requiring mandatory disclosure of MM short positions on all OTCBB listed stocks. In this manner, excessive shorting can be made known to the investing public, monitored for excess and corrected by the SEC/NASD. Then and only then can investors in these stocks be treated with the appropriate protection against fraud and manipulation.


Author: cyber-trading@austin.rr.com at Internet Date: 07/04/2000 11:37 AM Normal TO: RULE-COMMENTS at 03SEC Subject: Rule S7-24-99 ------------------------------- Message Contents On Tue Jul 4 11:37:30 2000, The following information was submitted: Host: 24.27.60.123 submit_by = cyber-trading@austin.rr.com Name = tuan hong Professional_Affiliation = Investor Subject = Short Sales (Release No. 34-42037; File No. S7-24-99) Comments = I am writing you this letter to show that I am in favor of the proposed Concept Release (No. 34-42037; File No. S7-24-99). It is known that the life blood of a small company is access to capital for creation and growth. It is also known that investors who place funds in such companies expect and deserve protection from fraud and manipulation. Small business is a critical building block for jobs and wealth in our economy. MMs have steadily been selling more shares than they have bought, defying the laws of supply and demand, solid company fundamentals and favorable company press releases, resulting in plummeting stock prices. The laws of supply and demand have been denied and investors deprived of fair value. Meanwhile, the company valuation of stock has been greatly reduced and with it, access to investment capital for acquisitions and growth. The MMs are supposed to provide a fair market trading mechanism, yet ,when they become invested through shorting, they actually have a vested interest in seeing the price fall. This practice must be brought under some form of control.  The Securities Act provides certain protective language as it relates to investors. Section 15A(b)(6) of the Securities Act says that the rules of a national securities association must be designed, among other things to prevent fraudulent and manipulative acts and practices and to protect investors and the public interest, and perfect the mechanism of a free and open market. Section 15A(b)(11) requires that association rules be designed to produce fair and information quotations, and to prevent fictitious and misleading quotations. In spite of the intent expressed by these two sections of the Securities Act, and unlike the Nasdaq, NYSE and AMEX, MMs are not required by the SEC to disclose short positions on OTCBB stocks. The MMs can short, even naked short, at will with no checks and balances on OTCBB stocks. This leaves the OTCBB listed companies prey to market manipulation on a scale only limited by the greed and imagination of the MMs. The MMs just keep selling the targeted companies stocks with the idea that they will never have to produce real shares. Their apparent goal is to force the company to fail by depriving it of working capital and discouraging investment. It is my belief billions of dollars are being stolen from investors in this manner. For the MMs, it's a wonderful business; sort of like selling insurance, but never having to pay claims. They get the money, but have no expense or expectation of delivering anything tangible in return. This unfair and counter productive practice cannot go on.  MMs must be held accountable by requiring mandatory disclosure of MM short positions on all OTCBB listed stocks. In this manner, excessive shorting can be made known to the investing public, monitored for excess and corrected by the SEC/NASD. Then and only then can investors in these stocks be treated with the appropriate protection against fraud and manipulation.


Author: hhussaini@england.com at Internet Date: 07/05/2000 11:25 AM Normal TO: RULE-COMMENTS at 03SEC Subject: Rule S7-24-99 ------------------------------- Message Contents On Wed Jul 5 11:25:33 2000, The following information was submitted: Host: 194.170.168.229 submit_by = hhussaini@england.com Name = ismail hussaini Professional_Affiliation = Investor Subject = Short Sales (Release No. 34-42037; File No. S7-24-99) Comments = I am writing you this letter to show that I am in favor of the proposed Concept Release (No. 34-42037; File No. S7-24-99). It is known that the life blood of a small company is access to capital for creation and growth. It is also known that investors who place funds in such companies expect and deserve protection from fraud and manipulation. Small business is a critical building block for jobs and wealth in our economy. MMs have steadily been selling more shares than they have bought, defying the laws of supply and demand, solid company fundamentals and favorable company press releases, resulting in plummeting stock prices. The laws of supply and demand have been denied and investors deprived of fair value. Meanwhile, the company valuation of stock has been greatly reduced and with it, access to investment capital for acquisitions and growth. The MMs are supposed to provide a fair market trading mechanism, yet ,when they become invested through shorting, they actually have a vested interest in seeing the price fall. This practice must be brought under some form of control.  The Securities Act provides certain protective language as it relates to investors. Section 15A(b)(6) of the Securities Act says that the rules of a national securities association must be designed, among other things to prevent fraudulent and manipulative acts and practices and to protect investors and the public interest, and perfect the mechanism of a free and open market. Section 15A(b)(11) requires that association rules be designed to produce fair and information quotations, and to prevent fictitious and misleading quotations. In spite of the intent expressed by these two sections of the Securities Act, and unlike the Nasdaq, NYSE and AMEX, MMs are not required by the SEC to disclose short positions on OTCBB stocks. The MMs can short, even naked short, at will with no checks and balances on OTCBB stocks. This leaves the OTCBB listed companies prey to market manipulation on a scale only limited by the greed and imagination of the MMs. The MMs just keep selling the targeted companies stocks with the idea that they will never have to produce real shares. Their apparent goal is to force the company to fail by depriving it of working capital and discouraging investment. It is my belief billions of dollars are being stolen from investors in this manner. For the MMs, it's a wonderful business; sort of like selling insurance, but never having to pay claims. They get the money, but have no expense or expectation of delivering anything tangible in return. This unfair and counter productive practice cannot go on.  MMs must be held accountable by requiring mandatory disclosure of MM short positions on all OTCBB listed stocks. In this manner, excessive shorting can be made known to the investing public, monitored for excess and corrected by the SEC/NASD. Then and only then can investors in these stocks be treated with the appropriate protection against fraud and manipulation. ex:loch


Author: barry6575@aol.com at Internet Date: 07/04/2000 8:30 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Rule S7-24-99 ------------------------------- Message Contents On Tue Jul 4 20:30:40 2000, The following information was submitted: Host: 152.163.205.21 submit_by = barry6575@aol.com Name = Barry Lancaster Professional_Affiliation = Investor Subject = Short Sales (Release No. 34-42037; File No. S7-24-99) Comments = I am writing you this letter to show that I am in favor of the proposed Concept Release (No. 34-42037; File No. S7-24-99). It is known that the life blood of a small company is access to capital for creation and growth. It is also known that investors who place funds in such companies expect and deserve protection from fraud and manipulation. Small business is a critical building block for jobs and wealth in our economy. MMs have steadily been selling more shares than they have bought, defying the laws of supply and demand, solid company fundamentals and favorable company press releases, resulting in plummeting stock prices. The laws of supply and demand have been denied and investors deprived of fair value. Meanwhile, the company valuation of stock has been greatly reduced and with it, access to investment capital for acquisitions and growth. The MMs are supposed to provide a fair market trading mechanism, yet ,when they become invested through shorting, they actually have a vested interest in seeing the price fall. This practice must be brought under some form of control.  The Securities Act provides certain protective language as it relates to investors. Section 15A(b)(6) of the Securities Act says that the rules of a national securities association must be designed, among other things to prevent fraudulent and manipulative acts and practices and to protect investors and the public interest, and perfect the mechanism of a free and open market. Section 15A(b)(11) requires that association rules be designed to produce fair and information quotations, and to prevent fictitious and misleading quotations. In spite of the intent expressed by these two sections of the Securities Act, and unlike the Nasdaq, NYSE and AMEX, MMs are not required by the SEC to disclose short positions on OTCBB stocks. The MMs can short, even naked short, at will with no checks and balances on OTCBB stocks. This leaves the OTCBB listed companies prey to market manipulation on a scale only limited by the greed and imagination of the MMs. The MMs just keep selling the targeted companies stocks with the idea that they will never have to produce real shares. Their apparent goal is to force the company to fail by depriving it of working capital and discouraging investment. It is my belief billions of dollars are being stolen from investors in this manner. For the MMs, it's a wonderful business; sort of like selling insurance, but never having to pay claims. They get the money, but have no expense or expectation of delivering anything tangible in return. This unfair and counter productive practice cannot go on.  MMs must be held accountable by requiring mandatory disclosure of MM short positions on all OTCBB listed stocks. In this manner, excessive shorting can be made known to the investing public, monitored for excess and corrected by the SEC/NASD. Then and only then can investors in these stocks be treated with the appropriate protection against fraud and manipulation.


Author: llasko@aol.com at Internet Date: 07/05/2000 7:13 AM Normal TO: RULE-COMMENTS at 03SEC Subject: Rule S7-24-99 ------------------------------- Message Contents On Wed Jul 5 07:13:35 2000, The following information was submitted: Host: 136.1.1.101 submit_by = llasko@aol.com Name = Louis J. Lasko Professional_Affiliation = Investor Subject = Short Sales (Release No. 34-42037; File No. S7-24-99) Comments = I am writing you this letter to show that I am in favor of the proposed Concept Release (No. 34-42037; File No. S7-24-99). It is known that the life blood of a small company is access to capital for creation and growth. It is also known that investors who place funds in such companies expect and deserve protection from fraud and manipulation. Small business is a critical building block for jobs and wealth in our economy. MMs have steadily been selling more shares than they have bought, defying the laws of supply and demand, solid company fundamentals and favorable company press releases, resulting in plummeting stock prices. The laws of supply and demand have been denied and investors deprived of fair value. Meanwhile, the company valuation of stock has been greatly reduced and with it, access to investment capital for acquisitions and growth. The MMs are supposed to provide a fair market trading mechanism, yet ,when they become invested through shorting, they actually have a vested interest in seeing the price fall. This practice must be brought under some form of control.  The Securities Act provides certain protective language as it relates to investors. Section 15A(b)(6) of the Securities Act says that the rules of a national securities association must be designed, among other things to prevent fraudulent and manipulative acts and practices and to protect investors and the public interest, and perfect the mechanism of a free and open market. Section 15A(b)(11) requires that association rules be designed to produce fair and information quotations, and to prevent fictitious and misleading quotations. In spite of the intent expressed by these two sections of the Securities Act, and unlike the Nasdaq, NYSE and AMEX, MMs are not required by the SEC to disclose short positions on OTCBB stocks. The MMs can short, even naked short, at will with no checks and balances on OTCBB stocks. This leaves the OTCBB listed companies prey to market manipulation on a scale only limited by the greed and imagination of the MMs. The MMs just keep selling the targeted companies stocks with the idea that they will never have to produce real shares. Their apparent goal is to force the company to fail by depriving it of working capital and discouraging investment. It is my belief billions of dollars are being stolen from investors in this manner. For the MMs, it's a wonderful business; sort of like selling insurance, but never having to pay claims. They get the money, but have no expense or expectation of delivering anything tangible in return. This unfair and counter productive practice cannot go on.  MMs must be held accountable by requiring mandatory disclosure of MM short positions on all OTCBB listed stocks. In this manner, excessive shorting can be made known to the investing public, monitored for excess and corrected by the SEC/NASD. Then and only then can investors in these stocks be treated with the appropriate protection against fraud and manipulation.


Author: lynchje@home.com at Internet Date: 07/05/2000 1:46 AM Normal TO: RULE-COMMENTS at 03SEC Subject: Rule S7-24-99 ------------------------------- Message Contents On Wed Jul 5 01:46:42 2000, The following information was submitted: Host: 24.4.252.72 submit_by = lynchje@home.com Name = James E Lynch Professional_Affiliation = Investor Subject = Short Sales (Release No. 34-42037; File No. S7-24-99) Comments = I am writing you this letter to show that I am in favor of the proposed Concept Release (No. 34-42037; File No. S7-24-99). It is known that the life blood of a small company is access to capital for creation and growth. It is also known that investors who place funds in such companies expect and deserve protection from fraud and manipulation. Small business is a critical building block for jobs and wealth in our economy. MMs have steadily been selling more shares than they have bought, defying the laws of supply and demand, solid company fundamentals and favorable company press releases, resulting in plummeting stock prices. The laws of supply and demand have been denied and investors deprived of fair value. Meanwhile, the company valuation of stock has been greatly reduced and with it, access to investment capital for acquisitions and growth. The MMs are supposed to provide a fair market trading mechanism, yet ,when they become invested through shorting, they actually have a vested interest in seeing the price fall. This practice must be brought under some form of control.  The Securities Act provides certain protective language as it relates to investors. Section 15A(b)(6) of the Securities Act says that the rules of a national securities association must be designed, among other things to prevent fraudulent and manipulative acts and practices and to protect investors and the public interest, and perfect the mechanism of a free and open market. Section 15A(b)(11) requires that association rules be designed to produce fair and information quotations, and to prevent fictitious and misleading quotations. In spite of the intent expressed by these two sections of the Securities Act, and unlike the Nasdaq, NYSE and AMEX, MMs are not required by the SEC to disclose short positions on OTCBB stocks. The MMs can short, even naked short, at will with no checks and balances on OTCBB stocks. This leaves the OTCBB listed companies prey to market manipulation on a scale only limited by the greed and imagination of the MMs. The MMs just keep selling the targeted companies stocks with the idea that they will never have to produce real shares. Their apparent goal is to force the company to fail by depriving it of working capital and discouraging investment. It is my belief billions of dollars are being stolen from investors in this manner. For the MMs, it's a wonderful business; sort of like selling insurance, but never having to pay claims. They get the money, but have no expense or expectation of delivering anything tangible in return. This unfair and counter productive practice cannot go on.  MMs must be held accountable by requiring mandatory disclosure of MM short positions on all OTCBB listed stocks. In this manner, excessive shorting can be made known to the investing public, monitored for excess and corrected by the SEC/NASD. Then and only then can investors in these stocks be treated with the appropriate protection against fraud and manipulation.


Author: lynchliz@home.com at Internet Date: 07/05/2000 1:44 AM Normal TO: RULE-COMMENTS at 03SEC Subject: Rule S7-24-99 ------------------------------- Message Contents On Wed Jul 5 01:44:42 2000, The following information was submitted: Host: 24.4.252.72 submit_by = lynchliz@home.com Name = Elizabeth V Lynch Professional_Affiliation = Investor Subject = Short Sales (Release No. 34-42037; File No. S7-24-99) Comments = I am writing you this letter to show that I am in favor of the proposed Concept Release (No. 34-42037; File No. S7-24-99). It is known that the life blood of a small company is access to capital for creation and growth. It is also known that investors who place funds in such companies expect and deserve protection from fraud and manipulation. Small business is a critical building block for jobs and wealth in our economy. MMs have steadily been selling more shares than they have bought, defying the laws of supply and demand, solid company fundamentals and favorable company press releases, resulting in plummeting stock prices. The laws of supply and demand have been denied and investors deprived of fair value. Meanwhile, the company valuation of stock has been greatly reduced and with it, access to investment capital for acquisitions and growth. The MMs are supposed to provide a fair market trading mechanism, yet ,when they become invested through shorting, they actually have a vested interest in seeing the price fall. This practice must be brought under some form of control.  The Securities Act provides certain protective language as it relates to investors. Section 15A(b)(6) of the Securities Act says that the rules of a national securities association must be designed, among other things to prevent fraudulent and manipulative acts and practices and to protect investors and the public interest, and perfect the mechanism of a free and open market. Section 15A(b)(11) requires that association rules be designed to produce fair and information quotations, and to prevent fictitious and misleading quotations. In spite of the intent expressed by these two sections of the Securities Act, and unlike the Nasdaq, NYSE and AMEX, MMs are not required by the SEC to disclose short positions on OTCBB stocks. The MMs can short, even naked short, at will with no checks and balances on OTCBB stocks. This leaves the OTCBB listed companies prey to market manipulation on a scale only limited by the greed and imagination of the MMs. The MMs just keep selling the targeted companies stocks with the idea that they will never have to produce real shares. Their apparent goal is to force the company to fail by depriving it of working capital and discouraging investment. It is my belief billions of dollars are being stolen from investors in this manner. For the MMs, it's a wonderful business; sort of like selling insurance, but never having to pay claims. They get the money, but have no expense or expectation of delivering anything tangible in return. This unfair and counter productive practice cannot go on.  MMs must be held accountable by requiring mandatory disclosure of MM short positions on all OTCBB listed stocks. In this manner, excessive shorting can be made known to the investing public, monitored for excess and corrected by the SEC/NASD. Then and only then can investors in these stocks be treated with the appropriate protection against fraud and manipulation.


Author: scottmacm@ragingbull.com at Internet Date: 07/04/2000 8:58 AM Normal TO: RULE-COMMENTS at 03SEC Subject: Rule S7-24-99 ------------------------------- Message Contents On Tue Jul 4 08:58:47 2000, The following information was submitted: Host: 209.86.186.72 submit_by = scottmacm@ragingbull.com Name = Scott MacMillan Professional_Affiliation = Investor Subject = Market Makers Comments = The idea that market makers ("MMs") do anything to benefit the markets, through short selling or otherwise, is outdated. It is not reasonable to believe that MMs contribute to an "efficient market" when their trading practices are so often coordinated and designed to benefit only themselves. Any benefit the markets might derive from the activities of MMs is pure coincidence. The MMs do not have any responsibility to provide benefits to the markets. There are no rules or regulations that require them to do so, or to make any effort to do so. To allow them to operate almost unchecked based on the premise that they "might" do something positive when their own behavior is intended to be self-serving is naive. Many investors are literally afraid to invested in OTCBB stocks because of the ability of MMs to manipulate those stocks. MMs should not be allowed to sell short in their own accounts. Their interests should, by law, have to be consistent with the interests of their clients. You are taking too long to deal with this matter. Public hearings are worthless when it comes to esoteric matters such as those at issue here. Most "investors" think "MM" is a candy, "M&Ms." The solution is simple: Change the rules so MMs cannot manipulate stock prices. You know many people object to "Big Brother" (the government) watching out for us, yet you put the MMs in that very role with respect to the markets. They watch out only for themselves. Thank you. Scott MacMillan 2400 N.W. 40th Circle Boca Raton, FL 33431


Author: kthlnirish@aol.com at Internet Date: 07/05/2000 9:34 AM Normal TO: RULE-COMMENTS at 03SEC Subject: Rule S7-24-99 ------------------------------- Message Contents On Wed Jul 5 09:34:09 2000, The following information was submitted: Host: 205.188.199.29 submit_by = kthlnirish@aol.com Name = kathleen mallon Professional_Affiliation = Investor Subject = Short Sales (Release No. 34-42037; File No. S7-24-99) Comments = I am writing you this letter to show that I am in favor of the proposed Concept Release (No. 34-42037; File No. S7-24-99). It is known that the life blood of a small company is access to capital for creation and growth. It is also known that investors who place funds in such companies expect and deserve protection from fraud and manipulation. Small business is a critical building block for jobs and wealth in our economy. MMs have steadily been selling more shares than they have bought, defying the laws of supply and demand, solid company fundamentals and favorable company press releases, resulting in plummeting stock prices. The laws of supply and demand have been denied and investors deprived of fair value. Meanwhile, the company valuation of stock has been greatly reduced and with it, access to investment capital for acquisitions and growth. The MMs are supposed to provide a fair market trading mechanism, yet ,when they become invested through shorting, they actually have a vested interest in seeing the price fall. This practice must be brought under some form of control.  The Securities Act provides certain protective language as it relates to investors. Section 15A(b)(6) of the Securities Act says that the rules of a national securities association must be designed, among other things to prevent fraudulent and manipulative acts and practices and to protect investors and the public interest, and perfect the mechanism of a free and open market. Section 15A(b)(11) requires that association rules be designed to produce fair and information quotations, and to prevent fictitious and misleading quotations. In spite of the intent expressed by these two sections of the Securities Act, and unlike the Nasdaq, NYSE and AMEX, MMs are not required by the SEC to disclose short positions on OTCBB stocks. The MMs can short, even naked short, at will with no checks and balances on OTCBB stocks. This leaves the OTCBB listed companies prey to market manipulation on a scale only limited by the greed and imagination of the MMs. The MMs just keep selling the targeted companies stocks with the idea that they will never have to produce real shares. Their apparent goal is to force the company to fail by depriving it of working capital and discouraging investment. It is my belief billions of dollars are being stolen from investors in this manner. For the MMs, it's a wonderful business; sort of like selling insurance, but never having to pay claims. They get the money, but have no expense or expectation of delivering anything tangible in return. This unfair and counter productive practice cannot go on.  MMs must be held accountable by requiring mandatory disclosure of MM short positions on all OTCBB listed stocks. In this manner, excessive shorting can be made known to the investing public, monitored for excess and corrected by the SEC/NASD. Then and only then can investors in these stocks be treated with the appropriate protection against fraud and manipulation.


Author: mayoro@nsu.law.nova.edu at Internet Date: 07/04/2000 11:23 AM Normal TO: RULE-COMMENTS at 03SEC Subject: Rule S7-24-99 ------------------------------- Message Contents On Tue Jul 4 11:23:47 2000, The following information was submitted: Host: 137.52.200.64 submit_by = mayoro@nsu.law.nova.edu Name = Orfelia Mayor Professional_Affiliation = Investor Subject = Short Sales (Release No. 34-42037; File No. S7-24-99) Comments = I am writing you this letter to show that I am in favor of the proposed Concept Release (No. 34-42037; File No. S7-24-99). It is known that the life blood of a small company is access to capital for creation and growth. It is also known that investors who place funds in such companies expect and deserve protection from fraud and manipulation. Small business is a critical building block for jobs and wealth in our economy. MMs have steadily been selling more shares than they have bought, defying the laws of supply and demand, solid company fundamentals and favorable company press releases, resulting in plummeting stock prices. The laws of supply and demand have been denied and investors deprived of fair value. Meanwhile, the company valuation of stock has been greatly reduced and with it, access to investment capital for acquisitions and growth. The MMs are supposed to provide a fair market trading mechanism, yet ,when they become invested through shorting, they actually have a vested interest in seeing the price fall. This practice must be brought under some form of control.  The Securities Act provides certain protective language as it relates to investors. Section 15A(b)(6) of the Securities Act says that the rules of a national securities association must be designed, among other things to prevent fraudulent and manipulative acts and practices and to protect investors and the public interest, and perfect the mechanism of a free and open market. Section 15A(b)(11) requires that association rules be designed to produce fair and information quotations, and to prevent fictitious and misleading quotations. In spite of the intent expressed by these two sections of the Securities Act, and unlike the Nasdaq, NYSE and AMEX, MMs are not required by the SEC to disclose short positions on OTCBB stocks. The MMs can short, even naked short, at will with no checks and balances on OTCBB stocks. This leaves the OTCBB listed companies prey to market manipulation on a scale only limited by the greed and imagination of the MMs. The MMs just keep selling the targeted companies stocks with the idea that they will never have to produce real shares. Their apparent goal is to force the company to fail by depriving it of working capital and discouraging investment. It is my belief billions of dollars are being stolen from investors in this manner. For the MMs, it's a wonderful business; sort of like selling insurance, but never having to pay claims. They get the money, but have no expense or expectation of delivering anything tangible in return. This unfair and counter productive practice cannot go on.  MMs must be held accountable by requiring mandatory disclosure of MM short positions on all OTCBB listed stocks. In this manner, excessive shorting can be made known to the investing public, monitored for excess and corrected by the SEC/NASD. Then and only then can investors in these stocks be treated with the appropriate protection against fraud and manipulation.


Author: melanco7@home.com at Internet Date: 07/04/2000 8:07 AM Normal TO: RULE-COMMENTS at 03SEC Subject: Rule S7-24-99 ------------------------------- Message Contents On Tue Jul 4 08:07:47 2000, The following information was submitted: Host: 24.4.254.164 submit_by = melanco7@home.com Name = Madelene D. Melancon Professional_Affiliation = Investor Subject = Short Sales (Release No. 34-42037; File No. S7-24-99) Comments = I am writing you this letter to show that I am in favor of the proposed Concept Release (No. 34-42037; File No. S7-24-99). It is known that the life blood of a small company is access to capital for creation and growth. It is also known that investors who place funds in such companies expect and deserve protection from fraud and manipulation. Small business is a critical building block for jobs and wealth in our economy. MMs have steadily been selling more shares than they have bought, defying the laws of supply and demand, solid company fundamentals and favorable company press releases, resulting in plummeting stock prices. The laws of supply and demand have been denied and investors deprived of fair value. Meanwhile, the company valuation of stock has been greatly reduced and with it, access to investment capital for acquisitions and growth. The MMs are supposed to provide a fair market trading mechanism, yet ,when they become invested through shorting, they actually have a vested interest in seeing the price fall. This practice must be brought under some form of control.  The Securities Act provides certain protective language as it relates to investors. Section 15A(b)(6) of the Securities Act says that the rules of a national securities association must be designed, among other things to prevent fraudulent and manipulative acts and practices and to protect investors and the public interest, and perfect the mechanism of a free and open market. Section 15A(b)(11) requires that association rules be designed to produce fair and information quotations, and to prevent fictitious and misleading quotations. In spite of the intent expressed by these two sections of the Securities Act, and unlike the Nasdaq, NYSE and AMEX, MMs are not required by the SEC to disclose short positions on OTCBB stocks. The MMs can short, even naked short, at will with no checks and balances on OTCBB stocks. This leaves the OTCBB listed companies prey to market manipulation on a scale only limited by the greed and imagination of the MMs. The MMs just keep selling the targeted companies stocks with the idea that they will never have to produce real shares. Their apparent goal is to force the company to fail by depriving it of working capital and discouraging investment. It is my belief billions of dollars are being stolen from investors in this manner. For the MMs, it's a wonderful business; sort of like selling insurance, but never having to pay claims. They get the money, but have no expense or expectation of delivering anything tangible in return. This unfair and counter productive practice cannot go on.  MMs must be held accountable by requiring mandatory disclosure of MM short positions on all OTCBB listed stocks. In this manner, excessive shorting can be made known to the investing public, monitored for excess and corrected by the SEC/NASD. Then and only then can investors in these stocks be treated with the appropriate protection against fraud and manipulation.


Author: eemoon@aol.com at Internet Date: 07/05/2000 10:57 AM Normal TO: RULE-COMMENTS at 03SEC Subject: Rule S7-24-99 ------------------------------- Message Contents On Wed Jul 5 10:57:57 2000, The following information was submitted: Host: 192.58.199.178 submit_by = eemoon@aol.com Name = Edward Earl Moon Professional_Affiliation = Investor Subject = Short Sales (Release No. 34-42037; File No. S7-24-99) Comments = I am writing you this letter to show that I am in favor of the proposed Concept Release (No. 34-42037; File No. S7-24-99). It is known that the life blood of a small company is access to capital for creation and growth. It is also known that investors who place funds in such companies expect and deserve protection from fraud and manipulation. Small business is a critical building block for jobs and wealth in our economy. MMs have steadily been selling more shares than they have bought, defying the laws of supply and demand, solid company fundamentals and favorable company press releases, resulting in plummeting stock prices. The laws of supply and demand have been denied and investors deprived of fair value. Meanwhile, the company valuation of stock has been greatly reduced and with it, access to investment capital for acquisitions and growth. The MMs are supposed to provide a fair market trading mechanism, yet ,when they become invested through shorting, they actually have a vested interest in seeing the price fall. This practice must be brought under some form of control.  The Securities Act provides certain protective language as it relates to investors. Section 15A(b)(6) of the Securities Act says that the rules of a national securities association must be designed, among other things to prevent fraudulent and manipulative acts and practices and to protect investors and the public interest, and perfect the mechanism of a free and open market. Section 15A(b)(11) requires that association rules be designed to produce fair and information quotations, and to prevent fictitious and misleading quotations. In spite of the intent expressed by these two sections of the Securities Act, and unlike the Nasdaq, NYSE and AMEX, MMs are not required by the SEC to disclose short positions on OTCBB stocks. The MMs can short, even naked short, at will with no checks and balances on OTCBB stocks. This leaves the OTCBB listed companies prey to market manipulation on a scale only limited by the greed and imagination of the MMs. The MMs just keep selling the targeted companies stocks with the idea that they will never have to produce real shares. Their apparent goal is to force the company to fail by depriving it of working capital and discouraging investment. It is my belief billions of dollars are being stolen from investors in this manner. For the MMs, it's a wonderful business; sort of like selling insurance, but never having to pay claims. They get the money, but have no expense or expectation of delivering anything tangible in return. This unfair and counter productive practice cannot go on.  MMs must be held accountable by requiring mandatory disclosure of MM short positions on all OTCBB listed stocks. In this manner, excessive shorting can be made known to the investing public, monitored for excess and corrected by the SEC/NASD. Then and only then can investors in these stocks be treated with the appropriate protection against fraud and manipulation.


Author: bpeters6@home.com at Internet Date: 07/05/2000 10:47 AM Normal TO: RULE-COMMENTS at 03SEC Subject: Rule S7-24-99 ------------------------------- Message Contents On Wed Jul 5 10:47:23 2000, The following information was submitted: Host: 216.58.126.158 submit_by = bpeters6@home.com Name = Robert Peters Professional_Affiliation = Investor Subject = Short Sales (Release No. 34-42037; File No. S7-24-99) Comments = I am writing you this letter to show that I am in favor of the proposed Concept Release (No. 34-42037; File No. S7-24-99). It is known that the life blood of a small company is access to capital for creation and growth. It is also known that investors who place funds in such companies expect and deserve protection from fraud and manipulation. Small business is a critical building block for jobs and wealth in our economy. MMs have steadily been selling more shares than they have bought, defying the laws of supply and demand, solid company fundamentals and favorable company press releases, resulting in plummeting stock prices. The laws of supply and demand have been denied and investors deprived of fair value. Meanwhile, the company valuation of stock has been greatly reduced and with it, access to investment capital for acquisitions and growth. The MMs are supposed to provide a fair market trading mechanism, yet ,when they become invested through shorting, they actually have a vested interest in seeing the price fall. This practice must be brought under some form of control.  The Securities Act provides certain protective language as it relates to investors. Section 15A(b)(6) of the Securities Act says that the rules of a national securities association must be designed, among other things to prevent fraudulent and manipulative acts and practices and to protect investors and the public interest, and perfect the mechanism of a free and open market. Section 15A(b)(11) requires that association rules be designed to produce fair and information quotations, and to prevent fictitious and misleading quotations. In spite of the intent expressed by these two sections of the Securities Act, and unlike the Nasdaq, NYSE and AMEX, MMs are not required by the SEC to disclose short positions on OTCBB stocks. The MMs can short, even naked short, at will with no checks and balances on OTCBB stocks. This leaves the OTCBB listed companies prey to market manipulation on a scale only limited by the greed and imagination of the MMs. The MMs just keep selling the targeted companies stocks with the idea that they will never have to produce real shares. Their apparent goal is to force the company to fail by depriving it of working capital and discouraging investment. It is my belief billions of dollars are being stolen from investors in this manner. For the MMs, it's a wonderful business; sort of like selling insurance, but never having to pay claims. They get the money, but have no expense or expectation of delivering anything tangible in return. This unfair and counter productive practice cannot go on.  MMs must be held accountable by requiring mandatory disclosure of MM short positions on all OTCBB listed stocks. In this manner, excessive shorting can be made known to the investing public, monitored for excess and corrected by the SEC/NASD. Then and only then can investors in these stocks be treated with the appropriate protection against fraud and manipulation.


Author: rapetty@attglobal.net at Internet Date: 07/04/2000 12:10 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Rule S7-24-99 ------------------------------- Message Contents On Tue Jul 4 12:10:12 2000, The following information was submitted: Host: 32.101.180.103 submit_by = rapetty@attglobal.net Name = Robert A. Petty Professional_Affiliation = Investor Subject = Short Sales (Release No. 34-42037; File No. S7-24-99) Comments = I am writing you this letter to show that I am in favor of the proposed Concept Release (No. 34-42037; File No. S7-24-99). It is known that the life blood of a small company is access to capital for creation and growth. It is also known that investors who place funds in such companies expect and deserve protection from fraud and manipulation. Small business is a critical building block for jobs and wealth in our economy. MMs have steadily been selling more shares than they have bought, defying the laws of supply and demand, solid company fundamentals and favorable company press releases, resulting in plummeting stock prices. The laws of supply and demand have been denied and investors deprived of fair value. Meanwhile, the company valuation of stock has been greatly reduced and with it, access to investment capital for acquisitions and growth. The MMs are supposed to provide a fair market trading mechanism, yet ,when they become invested through shorting, they actually have a vested interest in seeing the price fall. This practice must be brought under some form of control.  The Securities Act provides certain protective language as it relates to investors. Section 15A(b)(6) of the Securities Act says that the rules of a national securities association must be designed, among other things to prevent fraudulent and manipulative acts and practices and to protect investors and the public interest, and perfect the mechanism of a free and open market. Section 15A(b)(11) requires that association rules be designed to produce fair and information quotations, and to prevent fictitious and misleading quotations. In spite of the intent expressed by these two sections of the Securities Act, and unlike the Nasdaq, NYSE and AMEX, MMs are not required by the SEC to disclose short positions on OTCBB stocks. The MMs can short, even naked short, at will with no checks and balances on OTCBB stocks. This leaves the OTCBB listed companies prey to market manipulation on a scale only limited by the greed and imagination of the MMs. The MMs just keep selling the targeted companies stocks with the idea that they will never have to produce real shares. Their apparent goal is to force the company to fail by depriving it of working capital and discouraging investment. It is my belief billions of dollars are being stolen from investors in this manner. For the MMs, it's a wonderful business; sort of like selling insurance, but never having to pay claims. They get the money, but have no expense or expectation of delivering anything tangible in return. This unfair and counter productive practice cannot go on.  MMs must be held accountable by requiring mandatory disclosure of MM short positions on all OTCBB listed stocks. In this manner, excessive shorting can be made known to the investing public, monitored for excess and corrected by the SEC/NASD. Then and only then can investors in these stocks be treated with the appropriate protection against fraud and manipulation.


Author: ed.phillips@acsalaska.net at Internet Date: 07/04/2000 3:18 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Rule S7-24-99 ------------------------------- Message Contents On Tue Jul 4 15:18:13 2000, The following information was submitted: Host: 208.138.132.223 submit_by = ed.phillips@acsalaska.net Name = Edwin Phillips Professional_Affiliation = Investor Subject = Short Sales (Release No. 34-42037; File No. S7-24-99) Comments = I am writing first of all to tell you I am so tired of seeing unnatural movements in the over the conter stocks that I hold or an coerced to sell/buy. It is time to go to an electronic alternate trading system. The Money Market Manipulators are going to be impossible to avoid otherwise. Secondly, I am writing you this letter to show that I am in favor of the proposed Concept Release (No. 34-42037; File No. S7-24-99). It is known that the life blood of a small company is access to capital for creation and growth. It is also known that investors who place funds in such companies expect and deserve protection from fraud and manipulation. Small business is a critical building block for jobs and wealth in our economy. MMs have steadily been selling more shares than they have bought, defying the laws of supply and demand, solid company fundamentals and favorable company press releases, resulting in plummeting stock prices. The laws of supply and demand have been denied and investors deprived of fair value. Meanwhile, the company valuation of stock has been greatly reduced and with it, access to investment capital for acquisitions and growth. The MMs are supposed to provide a fair market trading mechanism, yet ,when they become invested through shorting, they actually have a vested interest in seeing the price fall. This practice must be brought under some form of control.  The Securities Act provides certain protective language as it relates to investors. Section 15A(b)(6) of the Securities Act says that the rules of a national securities association must be designed, among other things to prevent fraudulent and manipulative acts and practices and to protect investors and the public interest, and perfect the mechanism of a free and open market. Section 15A(b)(11) requires that association rules be designed to produce fair and information quotations, and to prevent fictitious and misleading quotations. In spite of the intent expressed by these two sections of the Securities Act, and unlike the Nasdaq, NYSE and AMEX, MMs are not required by the SEC to disclose short positions on OTCBB stocks. The MMs can short, even naked short, at will with no checks and balances on OTCBB stocks. This leaves the OTCBB listed companies prey to market manipulation on a scale only limited by the greed and imagination of the MMs. The MMs just keep selling the targeted companies stocks with the idea that they will never have to produce real shares. Their apparent goal is to force the company to fail by depriving it of working capital and discouraging investment. It is my belief billions of dollars are being stolen from investors in this manner. For the MMs, it's a wonderful business; sort of like selling insurance, but never having to pay claims. They get the money, but have no expense or expectation of delivering anything tangible in return. This unfair and counter productive practice cannot go on.  MMs must be held accountable by requiring mandatory disclosure of MM short positions on all OTCBB listed stocks. In this manner, excessive shorting can be made known to the investing public, monitored for excess and corrected by the SEC/NASD. Then and only then can investors in these stocks be treated with the appropriate protection against fraud and manipulation.


Author: "Marc J. Rabinowitz" at Internet Date: 07/03/2000 2:59 PM Normal TO: RULE-COMMENTS at 03SEC Subject: File No. S7-24-99 ------------------------------- Message Contents RE: Unregulated Short Sales by Market Makers on the OTCBB Dear Sirs: While I am generally in favor of less government intervention in our lives, I feel that it is necessary for stronger regularion of Market Makers in OTCBB securities. The lack of reporting requirements and other regulations allows a Market Maker to artificially hold down the price of a security. This practice gives rise to an investor's lack of confidence in the markets integrity. It also gives an appearance of impropriety, and scares some investors away. I urge you to enact stricter regulations on the OTCBB Market Makers and put back confidence in our markets. Thank you for your kind attention. Sincerely, Marc J. Rabinowitz, Esq.


Author: sirnasdaq@aol.com at Internet Date: 07/04/2000 4:24 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Rule S7-24-99 ------------------------------- Message Contents On Tue Jul 4 16:24:56 2000, The following information was submitted: Host: 152.163.207.64 submit_by = sirnasdaq@aol.com Name = Richard B. Roberts Professional_Affiliation = Investor Subject = Short Sales (Release No. 34-42037; File No. S7-24-99) Comments = I am writing you this letter to show that I am in favor of the proposed Concept Release (No. 34-42037; File No. S7-24-99). It is known that the life blood of a small company is access to capital for creation and growth. It is also known that investors who place funds in such companies expect and deserve protection from fraud and manipulation. Small business is a critical building block for jobs and wealth in our economy. MMs have steadily been selling more shares than they have bought, defying the laws of supply and demand, solid company fundamentals and favorable company press releases, resulting in plummeting stock prices. The laws of supply and demand have been denied and investors deprived of fair value. Meanwhile, the company valuation of stock has been greatly reduced and with it, access to investment capital for acquisitions and growth. The MMs are supposed to provide a fair market trading mechanism, yet ,when they become invested through shorting, they actually have a vested interest in seeing the price fall. This practice must be brought under some form of control.  The Securities Act provides certain protective language as it relates to investors. Section 15A(b)(6) of the Securities Act says that the rules of a national securities association must be designed, among other things to prevent fraudulent and manipulative acts and practices and to protect investors and the public interest, and perfect the mechanism of a free and open market. Section 15A(b)(11) requires that association rules be designed to produce fair and information quotations, and to prevent fictitious and misleading quotations. In spite of the intent expressed by these two sections of the Securities Act, and unlike the Nasdaq, NYSE and AMEX, MMs are not required by the SEC to disclose short positions on OTCBB stocks. The MMs can short, even naked short, at will with no checks and balances on OTCBB stocks. This leaves the OTCBB listed companies prey to market manipulation on a scale only limited by the greed and imagination of the MMs. The MMs just keep selling the targeted companies stocks with the idea that they will never have to produce real shares. Their apparent goal is to force the company to fail by depriving it of working capital and discouraging investment. It is my belief billions of dollars are being stolen from investors in this manner. For the MMs, it's a wonderful business; sort of like selling insurance, but never having to pay claims. They get the money, but have no expense or expectation of delivering anything tangible in return. This unfair and counter productive practice cannot go on.  MMs must be held accountable by requiring mandatory disclosure of MM short positions on all OTCBB listed stocks. In this manner, excessive shorting can be made known to the investing public, monitored for excess and corrected by the SEC/NASD. Then and only then can investors in these stocks be treated with the appropriate protection against fraud and manipulation.


Author: glr@glrconsulting.com at Internet Date: 07/04/2000 1:49 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Rule S7-24-99 ------------------------------- Message Contents On Tue Jul 4 13:49:32 2000, The following information was submitted: Host: 207.207.232.134 submit_by = glr@glrconsulting.com Name = Gary Rumble Professional_Affiliation = Investor Subject = Short Sales (Release No. 34-42037; File No. S7-24-99) Comments = I am writing you this letter to show that I am in favor of the proposed Concept Release (No. 34-42037; File No. S7-24-99). It is known that the life blood of a small company is access to capital for creation and growth. It is also known that investors who place funds in such companies expect and deserve protection from fraud and manipulation. Small business is a critical building block for jobs and wealth in our economy. MMs have steadily been selling more shares than they have bought, defying the laws of supply and demand, solid company fundamentals and favorable company press releases, resulting in plummeting stock prices. The laws of supply and demand have been denied and investors deprived of fair value. Meanwhile, the company valuation of stock has been greatly reduced and with it, access to investment capital for acquisitions and growth. The MMs are supposed to provide a fair market trading mechanism, yet ,when they become invested through shorting, they actually have a vested interest in seeing the price fall. This practice must be brought under some form of control.  The Securities Act provides certain protective language as it relates to investors. Section 15A(b)(6) of the Securities Act says that the rules of a national securities association must be designed, among other things to prevent fraudulent and manipulative acts and practices and to protect investors and the public interest, and perfect the mechanism of a free and open market. Section 15A(b)(11) requires that association rules be designed to produce fair and information quotations, and to prevent fictitious and misleading quotations. In spite of the intent expressed by these two sections of the Securities Act, and unlike the Nasdaq, NYSE and AMEX, MMs are not required by the SEC to disclose short positions on OTCBB stocks. The MMs can short, even naked short, at will with no checks and balances on OTCBB stocks. This leaves the OTCBB listed companies prey to market manipulation on a scale only limited by the greed and imagination of the MMs. The MMs just keep selling the targeted companies stocks with the idea that they will never have to produce real shares. Their apparent goal is to force the company to fail by depriving it of working capital and discouraging investment. It is my belief billions of dollars are being stolen from investors in this manner. For the MMs, it's a wonderful business; sort of like selling insurance, but never having to pay claims. They get the money, but have no expense or expectation of delivering anything tangible in return. This unfair and counter productive practice cannot go on.  MMs must be held accountable by requiring mandatory disclosure of MM short positions on all OTCBB listed stocks. In this manner, excessive shorting can be made known to the investing public, monitored for excess and corrected by the SEC/NASD. Then and only then can investors in these stocks be treated with the appropriate protection against fraud and manipulation.


Author: freeme2@usa.net at Internet Date: 07/05/2000 9:24 AM Normal TO: RULE-COMMENTS at 03SEC Subject: Rule S7-24-99 ------------------------------- Message Contents On Wed Jul 5 09:24:36 2000, The following information was submitted: Host: 209.131.14.1 submit_by = freeme2@usa.net Name = gary salata Professional_Affiliation = Investor Subject = Short Sales (Release No. 34-42037; File No. S7-24-99) Comments = I am writing you this letter to show that I am in favor of the proposed Concept Release (No. 34-42037; File No. S7-24-99). It is known that the life blood of a small company is access to capital for creation and growth. It is also known that investors who place funds in such companies expect and deserve protection from fraud and manipulation. Small business is a critical building block for jobs and wealth in our economy. MMs have steadily been selling more shares than they have bought, defying the laws of supply and demand, solid company fundamentals and favorable company press releases, resulting in plummeting stock prices. The laws of supply and demand have been denied and investors deprived of fair value. Meanwhile, the company valuation of stock has been greatly reduced and with it, access to investment capital for acquisitions and growth. The MMs are supposed to provide a fair market trading mechanism, yet ,when they become invested through shorting, they actually have a vested interest in seeing the price fall. This practice must be brought under some form of control.  The Securities Act provides certain protective language as it relates to investors. Section 15A(b)(6) of the Securities Act says that the rules of a national securities association must be designed, among other things to prevent fraudulent and manipulative acts and practices and to protect investors and the public interest, and perfect the mechanism of a free and open market. Section 15A(b)(11) requires that association rules be designed to produce fair and information quotations, and to prevent fictitious and misleading quotations. In spite of the intent expressed by these two sections of the Securities Act, and unlike the Nasdaq, NYSE and AMEX, MMs are not required by the SEC to disclose short positions on OTCBB stocks. The MMs can short, even naked short, at will with no checks and balances on OTCBB stocks. This leaves the OTCBB listed companies prey to market manipulation on a scale only limited by the greed and imagination of the MMs. The MMs just keep selling the targeted companies stocks with the idea that they will never have to produce real shares. Their apparent goal is to force the company to fail by depriving it of working capital and discouraging investment. It is my belief billions of dollars are being stolen from investors in this manner. For the MMs, it's a wonderful business; sort of like selling insurance, but never having to pay claims. They get the money, but have no expense or expectation of delivering anything tangible in return. This unfair and counter productive practice cannot go on.  MMs must be held accountable by requiring mandatory disclosure of MM short positions on all OTCBB listed stocks. In this manner, excessive shorting can be made known to the investing public, monitored for excess and corrected by the SEC/NASD. Then and only then can investors in these stocks be treated with the appropriate protection against fraud and manipulation.


Author: maverick@chesapeake.net at Internet Date: 07/05/2000 7:21 AM Normal TO: RULE-COMMENTS at 03SEC Subject: Rule S7-24-99 ------------------------------- Message Contents On Wed Jul 5 07:21:07 2000, The following information was submitted: Host: 4.17.82.17 submit_by = maverick@chesapeake.net Name = Barbara Scanlan Professional_Affiliation = Investor Subject = Short Sales (Release No. 34-42037; File No. S7-24-99) Comments = I am writing you this letter to show that I am in favor of the proposed Concept Release (No. 34-42037; File No. S7-24-99). It is known that the life blood of a small company is access to capital for creation and growth. It is also known that investors who place funds in such companies expect and deserve protection from fraud and manipulation. Small business is a critical building block for jobs and wealth in our economy. MMs have steadily been selling more shares than they have bought, defying the laws of supply and demand, solid company fundamentals and favorable company press releases, resulting in plummeting stock prices. The laws of supply and demand have been denied and investors deprived of fair value. Meanwhile, the company valuation of stock has been greatly reduced and with it, access to investment capital for acquisitions and growth. The MMs are supposed to provide a fair market trading mechanism, yet ,when they become invested through shorting, they actually have a vested interest in seeing the price fall. This practice must be brought under some form of control.  The Securities Act provides certain protective language as it relates to investors. Section 15A(b)(6) of the Securities Act says that the rules of a national securities association must be designed, among other things to prevent fraudulent and manipulative acts and practices and to protect investors and the public interest, and perfect the mechanism of a free and open market. Section 15A(b)(11) requires that association rules be designed to produce fair and information quotations, and to prevent fictitious and misleading quotations. In spite of the intent expressed by these two sections of the Securities Act, and unlike the Nasdaq, NYSE and AMEX, MMs are not required by the SEC to disclose short positions on OTCBB stocks. The MMs can short, even naked short, at will with no checks and balances on OTCBB stocks. This leaves the OTCBB listed companies prey to market manipulation on a scale only limited by the greed and imagination of the MMs. The MMs just keep selling the targeted companies stocks with the idea that they will never have to produce real shares. Their apparent goal is to force the company to fail by depriving it of working capital and discouraging investment. It is my belief billions of dollars are being stolen from investors in this manner. For the MMs, it's a wonderful business; sort of like selling insurance, but never having to pay claims. They get the money, but have no expense or expectation of delivering anything tangible in return. This unfair and counter productive practice cannot go on.  MMs must be held accountable by requiring mandatory disclosure of MM short positions on all OTCBB listed stocks. In this manner, excessive shorting can be made known to the investing public, monitored for excess and corrected by the SEC/NASD. Then and only then can investors in these stocks be treated with the appropriate protection against fraud and manipulation.


Author: mo999@home.com at Internet Date: 07/05/2000 1:48 AM Normal TO: RULE-COMMENTS at 03SEC Subject: Rule S7-24-99 ------------------------------- Message Contents On Wed Jul 5 01:48:05 2000, The following information was submitted: Host: 24.4.252.72 submit_by = mo999@home.com Name = Maurice K Shaw Professional_Affiliation = Investor Subject = Short Sales (Release No. 34-42037; File No. S7-24-99) Comments = I am writing you this letter to show that I am in favor of the proposed Concept Release (No. 34-42037; File No. S7-24-99). It is known that the life blood of a small company is access to capital for creation and growth. It is also known that investors who place funds in such companies expect and deserve protection from fraud and manipulation. Small business is a critical building block for jobs and wealth in our economy. MMs have steadily been selling more shares than they have bought, defying the laws of supply and demand, solid company fundamentals and favorable company press releases, resulting in plummeting stock prices. The laws of supply and demand have been denied and investors deprived of fair value. Meanwhile, the company valuation of stock has been greatly reduced and with it, access to investment capital for acquisitions and growth. The MMs are supposed to provide a fair market trading mechanism, yet ,when they become invested through shorting, they actually have a vested interest in seeing the price fall. This practice must be brought under some form of control.  The Securities Act provides certain protective language as it relates to investors. Section 15A(b)(6) of the Securities Act says that the rules of a national securities association must be designed, among other things to prevent fraudulent and manipulative acts and practices and to protect investors and the public interest, and perfect the mechanism of a free and open market. Section 15A(b)(11) requires that association rules be designed to produce fair and information quotations, and to prevent fictitious and misleading quotations. In spite of the intent expressed by these two sections of the Securities Act, and unlike the Nasdaq, NYSE and AMEX, MMs are not required by the SEC to disclose short positions on OTCBB stocks. The MMs can short, even naked short, at will with no checks and balances on OTCBB stocks. This leaves the OTCBB listed companies prey to market manipulation on a scale only limited by the greed and imagination of the MMs. The MMs just keep selling the targeted companies stocks with the idea that they will never have to produce real shares. Their apparent goal is to force the company to fail by depriving it of working capital and discouraging investment. It is my belief billions of dollars are being stolen from investors in this manner. For the MMs, it's a wonderful business; sort of like selling insurance, but never having to pay claims. They get the money, but have no expense or expectation of delivering anything tangible in return. This unfair and counter productive practice cannot go on.  MMs must be held accountable by requiring mandatory disclosure of MM short positions on all OTCBB listed stocks. In this manner, excessive shorting can be made known to the investing public, monitored for excess and corrected by the SEC/NASD. Then and only then can investors in these stocks be treated with the appropriate protection against fraud and manipulation.


Author: reid.shumate@gte.net at Internet Date: 07/05/2000 7:09 AM Normal TO: RULE-COMMENTS at 03SEC Subject: Rule S7-24-99 ------------------------------- Message Contents On Wed Jul 5 07:09:43 2000, The following information was submitted: Host: 4.3.32.232 submit_by = reid.shumate@gte.net Name = Reid Shumate Professional_Affiliation = Investor Subject = Short Sales (Release No. 34-42037; File No. S7-24-99) Comments = I am writing you this letter to show that I am in favor of the proposed Concept Release (No. 34-42037; File No. S7-24-99). It is known that the life blood of a small company is access to capital for creation and growth. It is also known that investors who place funds in such companies expect and deserve protection from fraud and manipulation. Small business is a critical building block for jobs and wealth in our economy. MMs have steadily been selling more shares than they have bought, defying the laws of supply and demand, solid company fundamentals and favorable company press releases, resulting in plummeting stock prices. The laws of supply and demand have been denied and investors deprived of fair value. Meanwhile, the company valuation of stock has been greatly reduced and with it, access to investment capital for acquisitions and growth. The MMs are supposed to provide a fair market trading mechanism, yet ,when they become invested through shorting, they actually have a vested interest in seeing the price fall. This practice must be brought under some form of control.  The Securities Act provides certain protective language as it relates to investors. Section 15A(b)(6) of the Securities Act says that the rules of a national securities association must be designed, among other things to prevent fraudulent and manipulative acts and practices and to protect investors and the public interest, and perfect the mechanism of a free and open market. Section 15A(b)(11) requires that association rules be designed to produce fair and information quotations, and to prevent fictitious and misleading quotations. In spite of the intent expressed by these two sections of the Securities Act, and unlike the Nasdaq, NYSE and AMEX, MMs are not required by the SEC to disclose short positions on OTCBB stocks. The MMs can short, even naked short, at will with no checks and balances on OTCBB stocks. This leaves the OTCBB listed companies prey to market manipulation on a scale only limited by the greed and imagination of the MMs. The MMs just keep selling the targeted companies stocks with the idea that they will never have to produce real shares. Their apparent goal is to force the company to fail by depriving it of working capital and discouraging investment. It is my belief billions of dollars are being stolen from investors in this manner. For the MMs, it's a wonderful business; sort of like selling insurance, but never having to pay claims. They get the money, but have no expense or expectation of delivering anything tangible in return. This unfair and counter productive practice cannot go on.  MMs must be held accountable by requiring mandatory disclosure of MM short positions on all OTCBB listed stocks. In this manner, excessive shorting can be made known to the investing public, monitored for excess and corrected by the SEC/NASD. Then and only then can investors in these stocks be treated with the appropriate protection against fraud and manipulation.


Author: jsilva1313@hotmail.com at Internet Date: 07/05/2000 7:48 AM Normal TO: RULE-COMMENTS at 03SEC Subject: Rule S7-24-99 ------------------------------- Message Contents On Wed Jul 5 07:48:45 2000, The following information was submitted: Host: 208.236.123.135 submit_by = jsilva1313@hotmail.com Name = John Silva Professional_Affiliation = Investor Subject = Short Sales (Release No. 34-42037; File No. S7-24-99) Comments = I am writing you this letter to show that I am in favor of the proposed Concept Release (No. 34-42037; File No. S7-24-99). It is known that the life blood of a small company is access to capital for creation and growth. It is also known that investors who place funds in such companies expect and deserve protection from fraud and manipulation. Small business is a critical building block for jobs and wealth in our economy. MMs have steadily been selling more shares than they have bought, defying the laws of supply and demand, solid company fundamentals and favorable company press releases, resulting in plummeting stock prices. The laws of supply and demand have been denied and investors deprived of fair value. Meanwhile, the company valuation of stock has been greatly reduced and with it, access to investment capital for acquisitions and growth. The MMs are supposed to provide a fair market trading mechanism, yet ,when they become invested through shorting, they actually have a vested interest in seeing the price fall. This practice must be brought under some form of control.  The Securities Act provides certain protective language as it relates to investors. Section 15A(b)(6) of the Securities Act says that the rules of a national securities association must be designed, among other things to prevent fraudulent and manipulative acts and practices and to protect investors and the public interest, and perfect the mechanism of a free and open market. Section 15A(b)(11) requires that association rules be designed to produce fair and information quotations, and to prevent fictitious and misleading quotations. In spite of the intent expressed by these two sections of the Securities Act, and unlike the Nasdaq, NYSE and AMEX, MMs are not required by the SEC to disclose short positions on OTCBB stocks. The MMs can short, even naked short, at will with no checks and balances on OTCBB stocks. This leaves the OTCBB listed companies prey to market manipulation on a scale only limited by the greed and imagination of the MMs. The MMs just keep selling the targeted companies stocks with the idea that they will never have to produce real shares. Their apparent goal is to force the company to fail by depriving it of working capital and discouraging investment. It is my belief billions of dollars are being stolen from investors in this manner. For the MMs, it's a wonderful business; sort of like selling insurance, but never having to pay claims. They get the money, but have no expense or expectation of delivering anything tangible in return. This unfair and counter productive practice cannot go on.  MMs must be held accountable by requiring mandatory disclosure of MM short positions on all OTCBB listed stocks. In this manner, excessive shorting can be made known to the investing public, monitored for excess and corrected by the SEC/NASD. Then and only then can investors in these stocks be treated with the appropriate protection against fraud and manipulation.


Author: JStea1@aol.com at Internet Date: 07/04/2000 12:24 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Rule S7-24-99 ------------------------------- Message Contents On Tue Jul 4 12:24:35 2000, The following information was submitted: Host: 205.188.192.156 submit_by = JStea1@aol.com Name = John Stea Professional_Affiliation = Investor Subject = Short Sales (Release No. 34-42037; File No. S7-24-99) Comments = I am writing you this letter to show that I am in favor of the proposed Concept Release (No. 34-42037; File No. S7-24-99). It is known that the life blood of a small company is access to capital for creation and growth. It is also known that investors who place funds in such companies expect and deserve protection from fraud and manipulation. Small business is a critical building block for jobs and wealth in our economy. MMs have steadily been selling more shares than they have bought, defying the laws of supply and demand, solid company fundamentals and favorable company press releases, resulting in plummeting stock prices. The laws of supply and demand have been denied and investors deprived of fair value. Meanwhile, the company valuation of stock has been greatly reduced and with it, access to investment capital for acquisitions and growth. The MMs are supposed to provide a fair market trading mechanism, yet ,when they become invested through shorting, they actually have a vested interest in seeing the price fall. This practice must be brought under some form of control.  The Securities Act provides certain protective language as it relates to investors. Section 15A(b)(6) of the Securities Act says that the rules of a national securities association must be designed, among other things to prevent fraudulent and manipulative acts and practices and to protect investors and the public interest, and perfect the mechanism of a free and open market. Section 15A(b)(11) requires that association rules be designed to produce fair and information quotations, and to prevent fictitious and misleading quotations. In spite of the intent expressed by these two sections of the Securities Act, and unlike the Nasdaq, NYSE and AMEX, MMs are not required by the SEC to disclose short positions on OTCBB stocks. The MMs can short, even naked short, at will with no checks and balances on OTCBB stocks. This leaves the OTCBB listed companies prey to market manipulation on a scale only limited by the greed and imagination of the MMs. The MMs just keep selling the targeted companies stocks with the idea that they will never have to produce real shares. Their apparent goal is to force the company to fail by depriving it of working capital and discouraging investment. It is my belief billions of dollars are being stolen from investors in this manner. For the MMs, it's a wonderful business; sort of like selling insurance, but never having to pay claims. They get the money, but have no expense or expectation of delivering anything tangible in return. This unfair and counter productive practice cannot go on.  MMs must be held accountable by requiring mandatory disclosure of MM short positions on all OTCBB listed stocks. In this manner, excessive shorting can be made known to the investing public, monitored for excess and corrected by the SEC/NASD. Then and only then can investors in these stocks be treated with the appropriate protection against fraud and manipulation.


Author: chas08@earthlink.net at Internet Date: 07/04/2000 8:26 PM Normal TO: RULE-COMMENTS at 03SEC Subject: Rule S7-24-99 ------------------------------- Message Contents On Tue Jul 4 20:26:31 2000, The following information was submitted: Host: 38.33.11.17 submit_by = chas08@earthlink.net Name = Charles Tapp Professional_Affiliation = Investor Subject = Short Sales (Release No. 34-42037; File No. S7-24-99) Comments = I am writing you this letter to show that I am in favor of the proposed Concept Release (No. 34-42037; File No. S7-24-99). It is known that the life blood of a small company is access to capital for creation and growth. It is also known that investors who place funds in such companies expect and deserve protection from fraud and manipulation. Small business is a critical building block for jobs and wealth in our economy. MMs have steadily been selling more shares than they have bought, defying the laws of supply and demand, solid company fundamentals and favorable company press releases, resulting in plummeting stock prices. The laws of supply and demand have been denied and investors deprived of fair value. Meanwhile, the company valuation of stock has been greatly reduced and with it, access to investment capital for acquisitions and growth. The MMs are supposed to provide a fair market trading mechanism, yet ,when they become invested through shorting, they actually have a vested interest in seeing the price fall. This practice must be brought under some form of control.  The Securities Act provides certain protective language as it relates to investors. Section 15A(b)(6) of the Securities Act says that the rules of a national securities association must be designed, among other things to prevent fraudulent and manipulative acts and practices and to protect investors and the public interest, and perfect the mechanism of a free and open market. Section 15A(b)(11) requires that association rules be designed to produce fair and information quotations, and to prevent fictitious and misleading quotations. In spite of the intent expressed by these two sections of the Securities Act, and unlike the Nasdaq, NYSE and AMEX, MMs are not required by the SEC to disclose short positions on OTCBB stocks. The MMs can short, even naked short, at will with no checks and balances on OTCBB stocks. This leaves the OTCBB listed companies prey to market manipulation on a scale only limited by the greed and imagination of the MMs. The MMs just keep selling the targeted companies stocks with the idea that they will never have to produce real shares. Their apparent goal is to force the company to fail by depriving it of working capital and discouraging investment. It is my belief billions of dollars are being stolen from investors in this manner. For the MMs, it's a wonderful business; sort of like selling insurance, but never having to pay claims. They get the money, but have no expense or expectation of delivering anything tangible in return. This unfair and counter productive practice cannot go on.  MMs must be held accountable by requiring mandatory disclosure of MM short positions on all OTCBB listed stocks. In this manner, excessive shorting can be made known to the investing public, monitored for excess and corrected by the SEC/NASD. Then and only then can investors in these stocks be treated with the appropriate protection against fraud and manipulation.


Author: wew_us@yahoo.com at Internet Date: 07/04/2000 10:43 AM Normal TO: RULE-COMMENTS at 03SEC Subject: Rule S7-24-99 ------------------------------- Message Contents On Tue Jul 4 10:43:37 2000, The following information was submitted: Host: 12.75.130.241 submit_by = wew_us@yahoo.com Name = Waldtraud E. Wahlquist Professional_Affiliation = Investor Subject = Short Sales (Release No. 34-42037; File No. S7-24-99) Comments = I am writing you this letter to show that I am in favor of the proposed Concept Release (No. 34-42037; File No. S7-24-99). It is known that the life blood of a small company is access to capital for creation and growth. It is also known that investors who place funds in such companies expect and deserve protection from fraud and manipulation. Small business is a critical building block for jobs and wealth in our economy. MMs have steadily been selling more shares than they have bought, defying the laws of supply and demand, solid company fundamentals and favorable company press releases, resulting in plummeting stock prices. The laws of supply and demand have been denied and investors deprived of fair value. Meanwhile, the company valuation of stock has been greatly reduced and with it, access to investment capital for acquisitions and growth. The MMs are supposed to provide a fair market trading mechanism, yet ,when they become invested through shorting, they actually have a vested interest in seeing the price fall. This practice must be brought under some form of control.  The Securities Act provides certain protective language as it relates to investors. Section 15A(b)(6) of the Securities Act says that the rules of a national securities association must be designed, among other things to prevent fraudulent and manipulative acts and practices and to protect investors and the public interest, and perfect the mechanism of a free and open market. Section 15A(b)(11) requires that association rules be designed to produce fair and information quotations, and to prevent fictitious and misleading quotations. In spite of the intent expressed by these two sections of the Securities Act, and unlike the Nasdaq, NYSE and AMEX, MMs are not required by the SEC to disclose short positions on OTCBB stocks. The MMs can short, even naked short, at will with no checks and balances on OTCBB stocks. This leaves the OTCBB listed companies prey to market manipulation on a scale only limited by the greed and imagination of the MMs. The MMs just keep selling the targeted companies stocks with the idea that they will never have to produce real shares. Their apparent goal is to force the company to fail by depriving it of working capital and discouraging investment. It is my belief billions of dollars are being stolen from investors in this manner. For the MMs, it's a wonderful business; sort of like selling insurance, but never having to pay claims. They get the money, but have no expense or expectation of delivering anything tangible in return. This unfair and counter productive practice cannot go on.  MMs must be held accountable by requiring mandatory disclosure of MM short positions on all OTCBB listed stocks. In this manner, excessive shorting can be made known to the investing public, monitored for excess and corrected by the SEC/NASD. Then and only then can investors in these stocks be treated with the appropriate protection against fraud and manipulation. Sincerely, Waldtraud E. Wahlquist


Author: wallingsg@home.com at Internet Date: 07/05/2000 1:47 AM Normal TO: RULE-COMMENTS at 03SEC Subject: Rule S7-24-99 ------------------------------- Message Contents On Wed Jul 5 01:47:28 2000, The following information was submitted: Host: 24.4.252.72 submit_by = wallingsg@home.com Name = Steven G Walling Professional_Affiliation = Investor Subject = Short Sales (Release No. 34-42037; File No. S7-24-99) Comments = I am writing you this letter to show that I am in favor of the proposed Concept Release (No. 34-42037; File No. S7-24-99). It is known that the life blood of a small company is access to capital for creation and growth. It is also known that investors who place funds in such companies expect and deserve protection from fraud and manipulation. Small business is a critical building block for jobs and wealth in our economy. MMs have steadily been selling more shares than they have bought, defying the laws of supply and demand, solid company fundamentals and favorable company press releases, resulting in plummeting stock prices. The laws of supply and demand have been denied and investors deprived of fair value. Meanwhile, the company valuation of stock has been greatly reduced and with it, access to investment capital for acquisitions and growth. The MMs are supposed to provide a fair market trading mechanism, yet ,when they become invested through shorting, they actually have a vested interest in seeing the price fall. This practice must be brought under some form of control.  The Securities Act provides certain protective language as it relates to investors. Section 15A(b)(6) of the Securities Act says that the rules of a national securities association must be designed, among other things to prevent fraudulent and manipulative acts and practices and to protect investors and the public interest, and perfect the mechanism of a free and open market. Section 15A(b)(11) requires that association rules be designed to produce fair and information quotations, and to prevent fictitious and misleading quotations. In spite of the intent expressed by these two sections of the Securities Act, and unlike the Nasdaq, NYSE and AMEX, MMs are not required by the SEC to disclose short positions on OTCBB stocks. The MMs can short, even naked short, at will with no checks and balances on OTCBB stocks. This leaves the OTCBB listed companies prey to market manipulation on a scale only limited by the greed and imagination of the MMs. The MMs just keep selling the targeted companies stocks with the idea that they will never have to produce real shares. Their apparent goal is to force the company to fail by depriving it of working capital and discouraging investment. It is my belief billions of dollars are being stolen from investors in this manner. For the MMs, it's a wonderful business; sort of like selling insurance, but never having to pay claims. They get the money, but have no expense or expectation of delivering anything tangible in return. This unfair and counter productive practice cannot go on.  MMs must be held accountable by requiring mandatory disclosure of MM short positions on all OTCBB listed stocks. In this manner, excessive shorting can be made known to the investing public, monitored for excess and corrected by the SEC/NASD. Then and only then can investors in these stocks be treated with the appropriate protection against fraud and manipulation.


Author: billyw1@tcainternet.com at Internet Date: 07/05/2000 9:53 AM Normal TO: RULE-COMMENTS at 03SEC Subject: Rule S7-24-99 ------------------------------- Message Contents On Wed Jul 5 09:53:33 2000, The following information was submitted: Host: 208.180.60.84 submit_by = billyw1@tcainternet.com Name = Billy E. Ward Professional_Affiliation = Investor Subject = Short Sales (Release No. 34-42037; File No. S7-24-99) Comments = I am writing you this letter to show that I am in favor of the proposed Concept Release (No. 34-42037; File No. S7-24-99). It is known that the life blood of a small company is access to capital for creation and growth. It is also known that investors who place funds in such companies expect and deserve protection from fraud and manipulation. Small business is a critical building block for jobs and wealth in our economy. MMs have steadily been selling more shares than they have bought, defying the laws of supply and demand, solid company fundamentals and favorable company press releases, resulting in plummeting stock prices. The laws of supply and demand have been denied and investors deprived of fair value. Meanwhile, the company valuation of stock has been greatly reduced and with it, access to investment capital for acquisitions and growth. The MMs are supposed to provide a fair market trading mechanism, yet ,when they become invested through shorting, they actually have a vested interest in seeing the price fall. This practice must be brought under some form of control.  The Securities Act provides certain protective language as it relates to investors. Section 15A(b)(6) of the Securities Act says that the rules of a national securities association must be designed, among other things to prevent fraudulent and manipulative acts and practices and to protect investors and the public interest, and perfect the mechanism of a free and open market. Section 15A(b)(11) requires that association rules be designed to produce fair and information quotations, and to prevent fictitious and misleading quotations. In spite of the intent expressed by these two sections of the Securities Act, and unlike the Nasdaq, NYSE and AMEX, MMs are not required by the SEC to disclose short positions on OTCBB stocks. The MMs can short, even naked short, at will with no checks and balances on OTCBB stocks. This leaves the OTCBB listed companies prey to market manipulation on a scale only limited by the greed and imagination of the MMs. The MMs just keep selling the targeted companies stocks with the idea that they will never have to produce real shares. Their apparent goal is to force the company to fail by depriving it of working capital and discouraging investment. It is my belief billions of dollars are being stolen from investors in this manner. For the MMs, it's a wonderful business; sort of like selling insurance, but never having to pay claims. They get the money, but have no expense or expectation of delivering anything tangible in return. This unfair and counter productive practice cannot go on.  MMs must be held accountable by requiring mandatory disclosure of MM short positions on all OTCBB listed stocks. In this manner, excessive shorting can be made known to the investing public, monitored for excess and corrected by the SEC/NASD. Then and only then can investors in these stocks be treated with the appropriate protection against fraud and manipulation.


Author: dlorah@home.com at Internet Date: 07/05/2000 4:36 AM Normal TO: RULE-COMMENTS at 03SEC Subject: Rule S7-24-99 ------------------------------- Message Contents On Wed Jul 5 04:36:53 2000, The following information was submitted: Host: 157.127.124.141 submit_by = dlorah@home.com Name = Harold William Wintemberg Professional_Affiliation = Investor Subject = Short Sales (Release No. 34-42037; File No. S7-24-99) Comments = I am writing you this letter to show that I am in favor of the proposed Concept Release (No. 34-42037; File No. S7-24-99). It is known that the life blood of a small company is access to capital for creation and growth. It is also known that investors who place funds in such companies expect and deserve protection from fraud and manipulation. Small business is a critical building block for jobs and wealth in our economy. MMs have steadily been selling more shares than they have bought, defying the laws of supply and demand, solid company fundamentals and favorable company press releases, resulting in plummeting stock prices. The laws of supply and demand have been denied and investors deprived of fair value. Meanwhile, the company valuation of stock has been greatly reduced and with it, access to investment capital for acquisitions and growth. The MMs are supposed to provide a fair market trading mechanism, yet ,when they become invested through shorting, they actually have a vested interest in seeing the price fall. This practice must be brought under some form of control.  The Securities Act provides certain protective language as it relates to investors. Section 15A(b)(6) of the Securities Act says that the rules of a national securities association must be designed, among other things to prevent fraudulent and manipulative acts and practices and to protect investors and the public interest, and perfect the mechanism of a free and open market. Section 15A(b)(11) requires that association rules be designed to produce fair and information quotations, and to prevent fictitious and misleading quotations. In spite of the intent expressed by these two sections of the Securities Act, and unlike the Nasdaq, NYSE and AMEX, MMs are not required by the SEC to disclose short positions on OTCBB stocks. The MMs can short, even naked short, at will with no checks and balances on OTCBB stocks. This leaves the OTCBB listed companies prey to market manipulation on a scale only limited by the greed and imagination of the MMs. The MMs just keep selling the targeted companies stocks with the idea that they will never have to produce real shares. Their apparent goal is to force the company to fail by depriving it of working capital and discouraging investment. It is my belief billions of dollars are being stolen from investors in this manner. For the MMs, it's a wonderful business; sort of like selling insurance, but never having to pay claims. They get the money, but have no expense or expectation of delivering anything tangible in return. This unfair and counter productive practice cannot go on.  MMs must be held accountable by requiring mandatory disclosure of MM short positions on all OTCBB listed stocks. In this manner, excessive shorting can be made known to the investing public, monitored for excess and corrected by the SEC/NASD. Then and only then can investors in these stocks be treated with the appropriate protection against fraud and manipulation.


Author: edward.zarate@ci.sj.ca.us at Internet Date: 07/04/2000 10:57 AM Normal TO: RULE-COMMENTS at 03SEC Subject: Rule S7-24-99 ------------------------------- Message Contents On Tue Jul 4 10:57:50 2000, The following information was submitted: Host: 156.39.136.220 submit_by = edward.zarate@ci.sj.ca.us Name = edward zarate Professional_Affiliation = Investor Subject = Short Sales (Release No. 34-42037; File No. S7-24-99) Comments = I am writing you this letter to show that I am in favor of the proposed Concept Release (No. 34-42037; File No. S7-24-99). It is known that the life blood of a small company is access to capital for creation and growth. It is also known that investors who place funds in such companies expect and deserve protection from fraud and manipulation. Small business is a critical building block for jobs and wealth in our economy. MMs have steadily been selling more shares than they have bought, defying the laws of supply and demand, solid company fundamentals and favorable company press releases, resulting in plummeting stock prices. The laws of supply and demand have been denied and investors deprived of fair value. Meanwhile, the company valuation of stock has been greatly reduced and with it, access to investment capital for acquisitions and growth. The MMs are supposed to provide a fair market trading mechanism, yet ,when they become invested through shorting, they actually have a vested interest in seeing the price fall. This practice must be brought under some form of control.  The Securities Act provides certain protective language as it relates to investors. Section 15A(b)(6) of the Securities Act says that the rules of a national securities association must be designed, among other things to prevent fraudulent and manipulative acts and practices and to protect investors and the public interest, and perfect the mechanism of a free and open market. Section 15A(b)(11) requires that association rules be designed to produce fair and information quotations, and to prevent fictitious and misleading quotations. In spite of the intent expressed by these two sections of the Securities Act, and unlike the Nasdaq, NYSE and AMEX, MMs are not required by the SEC to disclose short positions on OTCBB stocks. The MMs can short, even naked short, at will with no checks and balances on OTCBB stocks. This leaves the OTCBB listed companies prey to market manipulation on a scale only limited by the greed and imagination of the MMs. The MMs just keep selling the targeted companies stocks with the idea that they will never have to produce real shares. Their apparent goal is to force the company to fail by depriving it of working capital and discouraging investment. It is my belief billions of dollars are being stolen from investors in this manner. For the MMs, it's a wonderful business; sort of like selling insurance, but never having to pay claims. They get the money, but have no expense or expectation of delivering anything tangible in return. This unfair and counter productive practice cannot go on.  MMs must be held accountable by requiring mandatory disclosure of MM short positions on all OTCBB listed stocks. In this manner, excessive shorting can be made known to the investing public, monitored for excess and corrected by the SEC/NASD. Then and only then can investors in these stocks be treated with the appropriate protection against fraud and manipulation.

http://www.sec.gov/rules/0705b01.htm


Modified:07/06/2000