Subject: File No. S7-24-20
From: David Arkules
Affiliation: ARKULES FAMLY TRUST

December 29, 2020

I support the proposed an amendment to Rule 144 to revise the holding period determination for securities acquired upon the conversion or exchange of certain \"market-adjustable securities. In particular many public companies are borrowing and lenders are using Payment In Kind or PIK clauses that mislead retail investors on the underlying share value or company market cap.