Subject: File No. S7-24-99

Date:    09/14/2000 6:55 PM
     
     
The main problem I see with short sales is the 'naked short'.  Whereas I 
don't see where improvements can be made with normal short selling, 'naked' 
short selling can abnormally alter a stocks actions and I feel should not be 
allowed.  I know of one OTC stock in particular that has been grossly sold 
short 'naked'.  There is over 50 million shares short with no paper 
certificates from which to be borrowed from.  The stock is PCBM.  This 
hinders the normal liquidity and action of this stock.  It should be illegal 
and yet nothing is done to check the hands of the market makers on this.
     
Please respond.
Thank You
     
Ben Vaughn