From: Steven D. Albright
Sent: December 11, 2006
To: rule-comments@sec.gov
Subject: File No. SR-NASDAQ-2006-040


As CFO of Reliv International, Inc., a NASDAQ-listed company, Iím writing to oppose the proposed increase in listing fees that will in part pay for distribution of news releases via PrimeZone. If this proposal is approved, NASDAQ will automatically get a return on its investment in PrimeZone without having to earn it.

NASDAQ has taken a different approach with shareholder.com, offering listed companies a discount on shareholder.com services. Reliv uses shareholder.com in part because of the discount. But we had the choice to use it; we werenít forced to pay for services we werenít going to use.

The shareholder.com model is much better than the proposed PrimeZone model. If the PrimeZone model were approved, it would require listed companies to pay for services they do not want to use. It also would create a bad precedent. Suppose both NASDAQ and Company A wanted to buy Corporation B. NASDAQ would have an advantage over Company A because NASDAQ would know it could recoup part of its investment simply by raising listing fees.

Listed companies should have a choice in paying for outside services. NASDAQ should earn its return on its investments by making its acquired companies more competitive.

Steve Albright
Vice President and Chief Financial Officer
Reliv International, Inc