Date:    06/29/2000  10:55 AM

Subject: Release No. 34-42037

To whom it may concern
     
Rule 10a MUST be changed.  Understandably short sales are a necessary evil, 
however the rule governing it is too lax.  It allows market makers the 
opportunity to manipulate stock prices in the OTC:BB stocks as they please. 
Small investors, such as myself, are not even allowed to short sale a stock 
unless it's price is above a certain level, usually $4.00 to $5.00.  The market 
makers on the other hand can and do in an obvious market manipulating manner. 
They have created such an imbalance as to crash a stock for no other reason than
greed.  I have personally observed this in several stocks lately, Symphony 
Telecom Intl., Inc., (OTC:BB SYMY) by the market maker NITE and Medizone Intl., 
Inc. (OTC:BB MZEI) by the market maker ALEX.
     
I would suggest that the short sale requirement be equalized by allowing 
individual investors to short stock regardless of it's price the same as the 
market makers are allowed to.  However, this implies the plus tick rule be kept 
in place and I know the SEC is incapable of governing the market makers 
activities in this matter.
Maybe the simplest modification would be to require the market makers to file 
their short sales every month and set a minimum price for which they are allowed
to short sell.  The same price would apply for individual investors as well. 
Sincerely
     
Dennis J. Lissa