Date:    06/14/2000  4:06 PM

Subject: Selective Disclosure and Insider Trading, File No. S7-31-99
 
(Regarding File No. S7-31-99)
     
Members of the SEC:
     
I appreciate the opportunity to comment on this proposed rule.  There are two 
points that I wish the SEC to consider when making its rule.
     
     
1.  Selective disclosure creates conflict of interest between large 
institutions and/or brokerages and corporate management.
     
Institutions possess the ability to manipulate stock prices through bulk buying 
and selling, as well as through analyst recommendations.  Since stock and stock 
options are commonly used as part of executive compensation, and stock prices 
are commonly used as benchmarks for determining executive bonuses, there is a 
built-in incentive for executive management to curry favor with institutions at 
the expense of small investors.
     
Moreover, institutions also influence, through proportionately larger 
shareholder voting rights, the selection of corporation board members -- the 
very individuals who decide on hiring and compensation of executive management. 
     
Again, there is a built-in incentive for executive management to curry favor 
with the largest shareholders.
     
     
2.  Selective disclosure helps create the appearance that certain investors 
(brokerages and institutions) are favored over other (individual) investors.
     
Consider the recent decline of Citrix (Nasdaq: CTXS) stock between June 8 and 
June 12.  CTXS declined 46% on June 12 after Citrix issued a press release 
forecasting lower earnings than previously anticipated.  Yet this announcement 
was preceded by declines in CTXS stock of 14% on June 8 and 20% on June 9, 
despite no new public information.  It certainly appears to the casual observer 
that selective disclosure by Citrix management permitted large institutions to 
sell in advance of the June 12 announcement.
     
I am not a Citrix shareholder, and I have no specific knowledge that selective 
disclosure happened in this instance.  However, as an individual investor I am 
concerned that this practice may be more common than publicly acknowledged, and 
that this practice is condoned by the SEC in the absence of specific SEC rules 
to forbid such as this.
     
     
I do hope that the SEC will agree with me and forbid selective disclosure.
     
     
Sincerely,
     
     
-- Craig
Biggerstaff