April 25, 2013
Chairperson White and other Commissioners
The $1.00 per month nonprofessional subscriber fee for realtime data,included in this submission, is discriminatory against online investors. As such it is a a "per se" violation of anti-trust laws, protected only by Commission review.
This fee applies only to online investors: investors who access market data through their brokers' computers and web sites. Moreover much of the market data being accessed are bids, offers, and trade prices of these individual investors.
Not only do they need realtime data for making trading decisions, they also need such data to monitor the executions and limit order handling by their executing brokers.
I have submitted numerous comments and letters to the Commission that are included in The S7 files that argue this point in depth. Please incorporate them by reference in this comment. See especially Letters to Harvey Pitt, Arthur Levitt, and Christopher Cox and files S7-10-04, S7-40-04, and S7-24-89.
Former SEC Chief Economist (1969-1976) and Former NASD Chief Economist (1983-1995)