From: Terry E. Cohen [riter@writebyte.net]
Sent: Monday, January 05, 2004 10:07 PM
To: rule-comments@sec.gov
Subject: Proposed Regulation SHO - File No. S7-23-03

Dear Members of the SEC:
 
RE: Proposed Regulation SHO - File No. S7-23-03:
 
Today is January, 5, 2004...the deadline for comments on this proposed 
regulation.  I wish to add to my former email of comment that my Ameritrade 
screen shows that 1,853,660,765  shares of Pinnacle Business Management 
(PCBM) were traded today.
 
Most of these trades were executed at .0001 ask while the bid was zero.  
I have reviewed the log and most trades were an uptick at .0001, indicating 
buys, and there was NO upward price movement to correspond with the buying 
pressure.  How can this be regarded as making a bona fide market?  Was this 
incredible kind of volume of trading (buying) possible due to dilution not 
yet reported by the company OR was it due to naked short selling?
 
This underscores again the importance of NOT allowing market makers, 
broker-dealers or third-parties to be exempt from the proposed regulation.  
How can a need for liquidity justify this volume of trading?

I urge you again to tighten the regulations, define them measurably and 
without loopholes, and to apply them fairly to OTC/OTCBB/pink/grey microcaps 
as well as to larger NYSE, NASDAQ and AMEX companies.  Your mission is "to 
protect investors and maintain the integrity of the securities markets."
 
Sincerely,
T.E. Cohen
Maryland