Author:  "Martin E. Frankel" <drmef@mindspring.com> at Internet
Date:    12/15/1999  11:58 AM

Subject: File no. S7-24-99
 
I was delighted to see and read the proposed new SEC ruling regarding banning 
naked shorting of OTCBB stocks.
     
(1)  There is no logical or sound reason why investors in OTCBB stocks should 
not have the same protection as those that invest in companies listed on the 
Nasdaq or other major exchanges.  Investing in OTCBB stocks is speculative to 
begin with.  At the very least the playing field should be leveled so that 
market maker traders and offshore investors cannot blatantly naked short the 
shares of these companies and not only hurt the public investor, but also, in 
some instances, destroy a start-up company.  
     
(2)  Regarding the "uptick rule", I strongly believe this should be maintained 
as it is on every other exchange.  To do otherwise would open the door to "bear 
raids"... again hurting the common public investor while benefiting the 
"gameplayers".
     
There is far too much of this going on and it is time for it to be stopped. 
Thank your for your attention to this matter.  I can assure you that my 
sentiments are echoed by 99.99% of the public investors who do appreciate the 
efforts of the SEC to protect them against unfair practices.
     
Sincerely yours,
     
Dr. Martin E. Frankel