Peter Hajas
Chief Executive Officer
130 Cheshire Lane
Minnetonka, MN 55305
Tel: (612) 542-4200

November 15, 1999


Office of the Secretary
Securities and Exchange Commission
450 Fifth Street, N.W.
Washington DC 20549-6009
Attn: Mr. Jonathan G. Katz

Re: International Securities Exchange; File Number 10-127

Ladies and Gentlemen:

On October 20, 1999, the Securities and Exchange Commission ("SEC") issued a notice inviting additional comment on the International Securities Exchange's ("ISE") application for registration as a national securities exchange. We had previously commented on the ISE's application and appreciate the opportunity to submit these revised comments.
We previously noted our support for the ISE's mission-"to create and maintain an efficient, cost effective and liquid market for stock options through the introduction of a new market structure and automated trading systems." However, we commented negatively on the ISE's ownership structure. At that time, we were fearful that structure would not allow for a fair and competitive method for allocating memberships in the ISE and for the creation of a secondary market for the competitive purchase/allocation of memberships. Additionally, we were fearful that the concentration of membership interests in the ISE could create barriers to entry for other firms that wished to participate.

Since the time of our earlier comment letter, we have received assurances that the ISE desires widespread ownership and participation and we have learned that the ISE will provide for enhanced competition by providing more firms with the ability to be market makers in actively-traded stock options. In fact, access to the ISE is theoretically unlimited as the ISE's membership structure allows for an unlimited number of Electronic Access Members (a group of broker/dealer members that will not make markets but will be able to electronically place orders for their customers and proprietary orders for their own accounts).

In our earlier letter, we also raised concerns about the ownership structure of Adirondack Trading Partners LLC ("ATP") (investors in ATP include Ameritrade; E*TRADE; Herzog, Heine, Geduld, Inc.; Knight/Trimark Group, Inc.; and Scottsdale Securities). We now understand that ATP's corporate structure and strategy is patterned after Roundtable Partners ("Roundtable") and we support this ownership format. As you know, Roundtable was organized by a consortium of U.S. broker/dealers who grouped together to establish two equity market making operations, one for listed securities and one for OTC stocks. Roundtable has experienced tremendous success and now operates as Knight/Trimark Group, Inc. The basis of this success is the collective order flow of the broker/dealers who were original investors in Roundtable. Unlike equities, there is no third market for options; the creation of an exchange format is the only mechanism by which ATP can replicate the proven model created by Roundtable.

In short, we believe that the ISE will provide significant benefits to the investing public. As a general matter, the efficiencies of the ISE's trading system will benefit customers by providing a lower cost structure, which should lead to a reduction in hard-dollar trading costs. The greater efficiencies of the ISE's market also will result in quicker turn-around times for orders, decreasing the potential costs of missing markets.

Additionally, the ISE will provide significant advantages for market makers. For example, the ISE will be the only options exchange that requires every market maker to quote independently, in size, to compete for order flow. Also, the ISE's order-entry firms will have the ability to place proprietary orders on the ISE limit order book, which is not available in any other options market, and also will have the ability to trade anonymously. Moreover, the ISE's block trading systems offer new and efficient methods to trade large orders, both in seeking the possible participation of other ISE members in executing blocks and by allowing order entry firm's themselves to add their liquidity to block trades.

We support the ISE's application and urge the Commission to approve it promptly.
We thank you again for the opportunity to comment on the ISE's application. If you have any questions on our comments, please do not hesitate to contact us.

Very truly yours,


/s/ Peter Hajas

Peter Hajas
Chief Executive Officer