Date:    01/31/2000  6:12 AM

Subject: File No. S7-24-99 comments

Dear Sirs,
     
It is of crucial importance to maintaining fair and equitable 
markets that you level the playing field for the investing public.
     
I am specifically talking about short selling where the enforcement of one 
set of short-selling rules that apply to market makers and another to the 
investing public. It is time for you to remove the unfair one sided 
regulations, which restrict the public's ability to short-sell stocks, 
while allowing for preferential treatment for the market makers and 
industry insiders.
     
As I'm sure you are aware of, most novice investors do not understand or 
appreciate the critical checks and balances that short selling provides 
to allow the unimpeded flow of free markets. Since the industry makes
no effort to educate the public regarding short selling, the public 
is left to believe erroneously that it is short sellers who should 
be blamed when a stock goes down in price.
     
Unfortunately, this lack of understanding applies most directly to the 
new generation of investors who know little, spawned by the proliferation 
of instant access to information and gossip that the Internet allows. 
Many people use the Internet as a tool to generate "momentum" for stocks 
which creates a "snowball" effect on rapid runups in stocks. Many stocks 
run up solely on fabricated stories or rumor that have little or
nothing to do with the value of the underlying security.
     
However, professional investment firms and market makers have set the 
game up so they can play by a different set of rules than the general 
public.
They have done this only for their desire to make large amounts of money, 
under the umbrella of maintaining "fairness" in the market.
     
Every day, market pros short sell IPO's, short sell on downticks, and 
Short sell without regard to the availability of certificates. They do it 
quietly, without regulation, and without a requirement for disclosure; 
often in direct contradiction to the public "recommendations" of analysts 
from the very same firms.
     
The public will be best served by administering the markets so that every 
investor wishing to place their own money in an "at-risk" trade be allowed 
to do so under the same rules.
     
I urge you to eliminate current restrictions on short selling, and allow 
the public to sell short by the same rules as market makers.
     
Thank you for reviewing the facts of this crucial issue.
     
     
     Sincerely,

      Steven Kane