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Subject: Reference: Comments on proposed File No. S7-5-99

Date:    4/6/99 1:21 AM
     
     
I am the Chairman and CEO of a small Public Company, GC International, Inc 
listed on the OTC Bulletin Board. (GCIN).
I believe that adoption of the proposed rule will make it even more difficult 
for a small microcap company such as ours to ever develop a market and get our 
stock price to rise to a level that would qualify for National Market listing. 
We have one market maker who has stayed with us for a number of years thus 
providing some degree of liquidity for our small shareholders. All of this 
has been accomplished by the market maker with a view toward someday making 
some money as our company fortunes improve.
I believe that the proposed rule File No. S7-5-99 will make it impossible for 
GC to retain a market maker interested in our company if additional burdens 
are placed on the one place our stockhol;ders can go to buy or sell.
The obvious way to get rid of stock fraud is for the SEC to identify abuses 
and prosecute the people responsible, not go after legitimate businesses with 
a pile driver when a small hammer will do.
     
GC International, Inc.
F. Willard Griffith II
Chairman & CEO