Rule 14a-11 will be approved, 4-1, imho. I am hoping that the SEC applies 14a-11 provisions retroactively to enable us to nominate a candidate of our chosing in time for PTSC's Annual Shareholder Meeting scheduled for January 17, 2011

Unfortunately, the SEC has to consider the effect of the proposed Rule change on ALL reporting Companies, not just one OTCBB penny stock. Have you even contemplated the administrative and legal mayhem that would ensue should the Rule be made retroactive?

Because of the 120 day nomination window, I humbly suggest that the effective date will not be before 2011, and given a standard financial year of 1/1 to 12/31, sometime after the end of the first quarter for such companies i.e. not before 3/31, and more than likely after the second quarter end of 6/30.

Going forward, the 3% holding threshold should not be problematic as evidenced by the 20 million shares already pledged in d2006s' post. With those previosly pledged for the letter writing campaigns, the total pledged holdings should be in excess of 10%.

I, therefore, humbly suggest, that planning should start now to find suitable candidates for inclusion in any future proxy nominations in anticipation of the 3% Rule, if that is the intent.

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Be well