On Mon Jul 10 08:47:17 2000,
The following information was submitted: 
Host: 63.225.215.91
submit_by = jarmstro@nis4u.com
Name = James Burrought Armstrong
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 reasonable for investors who place funds in small publicly-held 
(over-the-counter; OTCBB) companies to expect the same protection from fraud and
manipulation as provided for large companies. Yet Market Makers (MM) have and 
abuse an opportunity to create just such manipulations, fraudulently depriving 
both company and investor of their rightful return on investment.
     
I'm sure you have received many other similar letters on this topic, so I will 
shorten my letter accordingly. 
     
Currently, MMs are not required by the SEC to disclose short positions on OTCBB 
stocks, in contrast to the Nasdaq, NYSE and AMEX. 
     
It is unreasonable for MMs not to be held similarly 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. In this way, investors in these stocks
(and the respective companies!) can be treated with the appropriate protection 
against fraud and manipulation. 
     
For that reason, and to echo the sentiments of thousands of other victimized 
investors, 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). 
     
James B. Armstrong
6 E. Tierra Buena Ln
Phoenix  AZ  85022-3029