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To: Zeev Hed who wrote (31533)	6/20/1999 11:34:00 PM
From: cicak	Respond to of 44908

Hi Zeev - would you agree that if Joseph G. Martinez (who appears to be the Counsel and Vice President for JAMAR Technologies, Inc.) is correct in his interpretation of SEC regulations: washlaw.edu biz.yahoo.com "The first, more fundamental, legal reason is that the SEC has taken the position that shares which were owned but which were not freely tradable when the short was created cannot later be used to cover the short postion, even though they have subsequently been included in a resale registration statement or, if not, have run the Rule 144 holding period. Conceptually, the SEC takes the position that the shares which were later delivered to cover the short had to have been in existence and freely tradable when the short was created because that is the time they were "sold" publicly." that the scenario you provided below would be in violation of SEC regulations ? Message 10194331 Regards, Phil