Date:    4/6/99  1:19 PM

Subject: S7-5-99

March 31, 1999
     
     
Jonathan G. Katz
Secretary, Securities and Exchange Commission 
Mail Stop 6-9
450 Fifth St., NW
Washington, DC 20549
     
Re: File No. S7-5-99
     
Dear Mr. Katz:
     
Please accept this letter in respectful opposition to proposed amendments 
to Rule 15c2-11.  While we feel that the amendment has good intentions by 
the SEC, we are also convinced that the passage of it would lead to 
irreparable harm to the market makers of OTC stocks and the companies 
listed therein, including ours, and therefore we must register our 
opposition to its passage.
     
Thank you for your consideration.
     
Regards,
     
     
     
David Webb, Director
Communications & Investor Relations
     
cc:     Arthur Levitt
        Isaac Hunt, Jr.
        Norman Johnson
        Paul R. Carey
        Laura Unger