Date:    12/22/1999  7:35 PM


Subject: S7-24-99

Dear SEC 
I am writing in regards to the proposed law concerning the
short selling of OTCBB stocks (Proposal #S7-24-77). The 
naked shorting of OTCBB stocks should b eliminated. One of 
the main reasons why "penny" stocks are so riskyis not soley 
because of the companies themselves. But because of the 
rampant naked shorting by market makers and offshore 
brokers. This activity goes unchecked every day and must be 
dealt with accordingly. The abolition of naked shorting in 
conjunction with the requirments of being fully reporting 
will ensure a fair and equitable market for investors and 
companies alike, a market where a company's ture value is 
reflected in the price and not distorted, suppressed or 
inflated artificially by
manipulation.                                    Sincerely,
     
     
Kenneth R Sponaugle