Date:    10/05/2000  10:28 PM

Subject: File No. S7-24-99
 
Dear Mr. Katz:
     
I strongly believe that Rule 10a-1 (short sales only allowed on upticks) should 
be eliminated.  Rule 10a-1:
     
1) frequently prevents a willing seller and a willing buyer from meeting.  Often
I have wanted to short a stock at the bid price.  Even though there were willing
buyers at the bid price, rule 10a-1 prevented me from selling shares to them. 
Rule 10a-1 creates unnatural roadblocks to transacting business, thereby 
decreasing liquidity in the marketplace
     
2) is unfair to the investing public such as myself because it applies to the 
public but not to market makers.  Elimination of rule 10a-1 would be another 
welcome step in the continued leveling of the playing field that the SEC has 
been advocating.
     
Thank you for your consideration.
Chris Erickson