Date:    02/01/2000  10:34 AM

Subject: File # S7-24-99

Dear Sirs:
     
I would like to take this opportunity to provide you my comments on your 
Short Sales concept release.  In very simple terms, the SEC needs to move 
to tighten controls on short sales, if not eliminate their wide spread 
availability.  While it may be true that market makers use the short sale 
to make up for temporary short falls in supply, that action does not 
necessarily provide for proper valuation of the underlying security.  When 
demand exceeds supply, the price should rise, not be held down due to short 
selling.
     
My real concern, however, is the use of short sales as a panic tool by bear 
raiders.  Organizations with access to large supplies of capital can force 
down a stock price to create a retail panic.  This spiral effect hurts the 
retail investor and allows the short sellers to cover at a price that is 
artificially low.  This is, by definition, manipulation.
     
Lastly, I believe the anonymous short selling provided by Instinet needs to 
be completely halted.  All transactions need to be made public, including 
short sales.
     
Thanks you for your consideration.
     
David Jimenez