Date:    12/23/1999  8:11 AM


Subject: File No. S7-24-99 
To SEC:
  RE:  CFR Part 240
       Release No. 94-42037; 
       RIN 3235 - AH84
       Short Sales
     
Greetings:
     
I in total support of the changes requiring all companies traded on the 
OTCBB to file regular 10-Q and 10-K with the SEC.  In addition I 
strongly urge the Short Sale rules be extended to Non-Exchange Listed 
securities.
(Nasd. Small Cap, Nasd's OTCBB, pink sheets).  This action would lessen 
the manipulation of market makers, and use of "naked Shorting", which 
would provide a more reasonable and orderly market, which relflects a 
more realistic valuation of publicly traded stocks.
     
Thank you for your attention.
     
Michael Sobiloff
Investor