SCIENTIFIC TECHNOLOGIES, INC. Suite # 1455 - 409 Granville St., Vancouver, B.C., Canada V6C 1T2 Tel: (604) 685-0364 Fax: (604) 689-8337_ April 6, 1999 By: EMAIL Mr. Jonathan G. Katz Secretary Securities Exchange Commission Mail Stop 6-9 450 Fifth Street Washington, D.C. 20549 RE: Amendments to Rule 15C2-11 File No. S7-5-99 Dear Mr. Katz: Our understanding of the proposed rule amendments is that they would require market makers in OTC Bulletin Board and Pink Sheet stocks to learn about the stocks they trade, study the companiesâ_T financial statements, and keep an eye out for fraud. I am sure that legitimate market makers already do learn about the stocks they trade but it is blatantly unfair to put them in a position of regulating and policing . Maybe that is not the intention of the proposed amendments but if they result in this situation, then, defacto, the SEC will be shifting its responsibilities to market makers. We are a small but fast growing high technology manufacturer. We recently commenced trading on the OTC Pink Sheets with the intention of moving first to the Bulletin Board and then NASDAQ. We decided to go the public route to gain better access to financial markets and to provide liquidity for our shareholders. It was acknowledged that the road ahead would be full of challenges, and we were fully confident in our ability to meet them. However, the proposed amendments, if enacted could seriously impede our progress by taking away market maker support. - 2 - I would ask you to seriously consider the damage these amendments would cause to legitimate, up and coming companies such as ours. Thank you. SCIENTIFIC TECHNOLOGIES, INC. Wilson E. Russell President/CEO WER:mm cc: Mr. Arthur Levitt Chairman, SEC SCIENTIFIC TECHNOLOGIES, INC. Suite # 1455 - 409 Granville St., Vancouver, B.C., Canada V6C 1T2 Tel: (604) 685-0364 Fax: (604) 689-8337_ April 6, 1999 By: EMAIL Mr. Jonathan G. Katz Secretary Securities Exchange Commission Mail Stop 6-9 450 Fifth Street Washington, D.C. 20549 RE: Amendments to Rule 15C2-11 File No. S7-5-99 Dear Mr. Katz: Our understanding of the proposed rule amendments is that they would require market makers in OTC Bulletin Board and Pink Sheet stocks to learn about the stocks they trade, study the companiesâ_T financial statements, and keep an eye out for fraud. I am sure that legitimate market makers already do learn about the stocks they trade but it is blatantly unfair to put them in a position of regulating and policing . Maybe that is not the intention of the proposed amendments but if they result in this situation, then, defacto, the SEC will be shifting its responsibilities to market makers. We are a small but fast growing high technology manufacturer. We recently commenced trading on the OTC Pink Sheets with the intention of moving first to the Bulletin Board and then NASDAQ. We decided to go the public route to gain better access to financial markets and to provide liquidity for our shareholders. It was acknowledged that the road ahead would be full of challenges, and we were fully confident in our ability to meet them. However, the proposed amendments, if enacted could seriously impede our progress by taking away market maker support. - 2 - I would ask you to seriously consider the damage these amendments would cause to legitimate, up and coming companies such as ours. Thank you. SCIENTIFIC TECHNOLOGIES, INC. Wilson E. Russell President/CEO WER:mm cc: Mr. Arthur Levitt Chairman, SEC SCIENTIFIC TECHNOLOGIES, INC. Suite # 1455 - 409 Granville St., Vancouver, B.C., Canada V6C 1T2 Tel: (604) 685-0364 Fax: (604) 689-8337_ April 6, 1999 By: EMAIL Mr. Jonathan G. Katz Secretary Securities Exchange Commission Mail Stop 6-9 450 Fifth Street Washington, D.C. 20549 RE: Amendments to Rule 15C2-11 File No. S7-5-99 Dear Mr. Katz: Our understanding of the proposed rule amendments is that they would require market makers in OTC Bulletin Board and Pink Sheet stocks to learn about the stocks they trade, study the companiesâ_T financial statements, and keep an eye out for fraud. I am sure that legitimate market makers already do learn about the stocks they trade but it is blatantly unfair to put them in a position of regulating and policing . Maybe that is not the intention of the proposed amendments but if they result in this situation, then, defacto, the SEC will be shifting its responsibilities to market makers. We are a small but fast growing high technology manufacturer. We recently commenced trading on the OTC Pink Sheets with the intention of moving first to the Bulletin Board and then NASDAQ. We decided to go the public route to gain better access to financial markets and to provide liquidity for our shareholders. It was acknowledged that the road ahead would be full of challenges, and we were fully confident in our ability to meet them. However, the proposed amendments, if enacted could seriously impede our progress by taking away market maker support. - 2 - I would ask you to seriously consider the damage these amendments would cause to legitimate, up and coming companies such as ours. Thank you. SCIENTIFIC TECHNOLOGIES, INC. Wilson E. Russell President/CEO WER:mm cc: Mr. Arthur Levitt Chairman, SEC