Date:    06/25/2000  9:59 PM

Subject: File No. S7-24-99  

 From the SEC rules:
Short selling provides the market with two important benefits: market 
liquidity and pricing efficiency.
     
HOGWASH!!!! Especially as it pertains to OTC BB securities.
Fact: SEC is understaffed and overwhelmed in relation to regulating 
securities markets.
Fact: Even with that hurdle the SEC does a excellent job of regulation. 
FACT: Sometimes when something is as plain as the nose on one's face, the 
SEC takes much too long in revising or creating a new law.
     
I would like to publicly state that "naked short selling" of OTC BB 
securities should NOT BE ALLOWED!!!!!!!!!!!!
     
The example of a security I am talking about is Tirex Corporation (TXMC). 
I will leave it up to your market surveillance analysts to review the 1) 
time & sales,
2) bid/ask, 3) order size, 4) total volume ask vs bid (especially) over the 
last three months to verify how the MM's have manipulated the price of TXMC 
to their own advantage at the expense of individual shareholders.
     
In March of 2000, Tirex had a major pr announcing the viability of their 
tire recylcing
technology. Based on a true market the price flucated fairly based on 
orders coming into various brokers, MM's.
     
Later that month, a negative pr regarding a lawsuit reversed that trend and 
subsquently the price fell. Fair enough.
     
However, on a continuous basis there have been NUMEROUS times the ask volume 
has outstripped the bid volume and the price has dropped. How so??
By a few active MM's lowering the ask and at times the bid / ask locking or 
even the bid being higher than the ask. Explain that to me? That is not 
market liquidity nor is it pricing efficiency.
     
On the other hand, I have watch the time & sales while a 1000 sh ask & a 
200 sh bid order go through with the price dropping.
This is also not market liquidity nor pricing efficiency.
     
I could give you dates but it would be easier for you to look at every day 
for the last three months.
     
While somewhat related, I have put limit ask orders above the then current 
ask, insuring that I don't pay more than I want. What happens, the security 
trades at the
current ask, I see my "lone" order go through at my LIMIT price and the ask 
then drops back to the previous current ask. The size was the same for all 
trades.
     
I feel the Market Makers are not only taking advantage of sophistated 
investors who have diligently research a security such as Tirex and believe 
in the company but are more importantly are ripping investors off who do not 
have full knowledge of the market and have bought on advice of others. Yes, 
buyer beware but a more important saying is "don't bite the hand that feeds 
you"
     
Someday the tables will turn > when this naked short rule is changed and 
when it is,
then investors will be able to fairly trade securities and hopefully profit 
from it.
An added benefit will be the unscrupulous BB companies that are not fully 
reporting
and without legitimate products or services will also be exposed.
(MM's will short those stocks - rightfully so, but investors will be fully 
informed.)
     
If you don't agree with the above statements then let individual investors 
short sell bulletin board stocks. Because then I will short sell and wait 
for the MM to bring the price down in their usual ripoff mode and make some 
money.
Only difference is, I would be more than willing to email all my friends & 
the SEC to let them know what I am going to do.
     
Sincerely,
   Jerome T. Leon