File No. 4-430

To: Jonathan Katz
Secretary,
Securities Exchange Commission
450 Fifth Street NW
Washington DC 20549-0609

Dear Mr. Katz:

Enclosed are Telekurs Financials' comments on the Revised Decimal Implementation Schedules proposed in Release No. 34-42685/April 13, 2000, File No. 4-430.

Telekurs Financial Information Ltd. located in Zurich, Switzerland is part of the Telekurs Group, an acknowledged leader in financial information services. Established in 1930, Telekurs has offices in 10 major financial centers around the globe.

Telekurs Financial offers both North American and international market data feed, from over 210 exchanges and 400 third-party contributors. Telekurs' Market Data Feed serves real-time and non-real-time data via our terminals to hundreds of financial and non-financial institutions around the world.

1. Is it feasible to begin Dual Pricing by September 4, 2000? If it is feasible, should trading in all exchange-listed securities be in nickel or penny increments? If it is not feasible to begin Dual Pricing by September 4, 2000, why not?

Telekurs Financials' response:

Yes, it is feasible for Telekurs to begin dual pricing by September 4, 2000. We received a letter from SIAC (Securities Industry Automation Corporation) dated February 17, 2000 informing us that the message rate capacity for OPRA will increase from the current 3500 Mps to 8000 Mps by April 2000 and to 12,000 Mps by early 3rd Quarter 2000. This is prior to the introduction of decimals. Therefore, it is advisable to implement decimalization using a phased approach. An acceptable approach is to first implement trading of large number of exchange-listed securities in nickels. After a thorough evaluation of its impact on system and line capacity, implement decimals in penny increments at a later stage.

Regarding dual pricing of exchange related securities, we advise that all US exchanges migrate to nickels before they migrate to pennies. We also suggest that CTS/CQS, OPRA and NASDAQ implement decimals in nickels at the same time.

2. What if any, system changes or other steps would be necessary to implement Dual Pricing by this September 4, 2000 deadline? What type of changes would need to be made to the systems of securities firms, investment companies and vendors? What would be the impact on systems capacity? In light of your answers to the foregoing questions, what changes would need to be made to the current decimals testing schedule?

Telekurs Financials' response:

The steps were required to implement Dual Pricing by September 4, 2000:

a) Hardware:

Telekurs Financial evaluated the projected increase in message rates and decided to upgrade their hardware to facilitate the processing of large volumes of data. The upgrade cost will be approximately $200,000.

b) Communication lines:

Telekurs migrated to T 3 lines, in order to accommodate high traffic peaks and increased trading volumes. In addition, Telekurs has to ensure that all necessary lines are in place to transmit this information from NY to our local office in Stamford and then via our backbone network to Zurich. The additional cost of installing T 3 lines in the U.S. will be approximately $250,000 per annum. This does not take into consideration communication line costs to transmit this information around the globe.

c) Software:

Currently, Telekurs converts all traded information into decimals. Therefore, migration to decimals would require making adjustments to the
exchange formats and ensuring that we display the prices accurately. It will take us approximately 6 man months to implement decimals. This will cost us approximately $250,000.

Once we have completed the testing and quality assurance of securities traded in nickels, we will be able to implement decimals as per the testing schedule set up in the industry by the SIA Testing Committee. We suggest that we first trade securities in nickels before we implement pennies. This will create less confusion in the market.

3. Is the risk of customer confusion between dual pricing significant, and if so how should it be addressed?

Telekurs Financials' response:

Since we currently process all traded and quoted information in decimals for all securities, our customers will not be confused with Dual Pricing.

4. If commenters believe that implementing Dual Pricing by September 4, 2000 is not feasible, what date(s) is (are) feasible to implement Dual Pricing? Commenters should include a discussion of the system changes and testing schedules that would be needed for their alternative.

Telekurs Financials' response:

Not applicable.

5. In addition, if commenters believe that implementing Dual Pricing by September 4, 2000 is not feasible, is the alternative Decimals Pilot proposal feasible or preferable?
If Commenters believe that the Decimal Pilot is feasible, what if any systems changes or other steps would be necessary to facilitate this schedule? In particular what changes would need to be made to the systems of securities firms, investment companies and vendors? What would be the impact on systems capacity? Is there a risk of customer confusion and if so how should this be addressed?

Telekurs Financials' response:

Decimal Pilot is feasible. Please refer to Telekurs response above in 2 (a, b and c).

Since Telekurs currently provides all traded information in decimals, we believe that there will be minimum confusion and risk associated with Dual Pricing for our customers.

However, to evaluate the true impact of securities trading in increments of nickels or with Dual Pricing, it is necessary to increase the number of securities being tested in the Pilot program to a larger universe. In addition, we will have to prepare and upgrade our infrastructure in order to process over 12000 Mps by the beginning of the 3rd quarter. This is a five-fold increase in the volume of securities traded. Currently, Telekurs is testing
T 3 lines and this will help us process the increased volume of information. In order to ensure an accurate evaluation, it is advisable to first implement trading in nickels by March 31, 2001 and then implement pennies in the next phase by June 2001.

6. If commenters believe that Decimals Pilot is not feasible, what alternatives would expedite the implementation of decimal pricing in exchange-listed and NASDAQ securities? Commenters should include discussion of the system changes and testing schedules that would be needed for their alternative, including implementation date(s).

Telekurs Financials' response:

Not applicable

7. Commenters are requested to offer specific views on the optimal schedule for implementing decimal pricing in options based on exchange-listed and NASDAQ stocks subject to decimal pricing.

Telekurs Financials' response:

Telekurs will follow the testing schedule provided by the SIA Testing Committee. We do not anticipate any issues related to the implementation of decimals for options, since Telekurs currently provides all prices in decimals.

The issue we are concerned with is that decimalization will increase the volume of information and this will increase the cost of upgrading hardware and communication lines between the United States and the countries where this information is being transmitted.

We strongly advise you to first evaluate and test securities traded in nickels, before we implement exchange-listed securities trading in pennies. We need to also consider capacity, trading volumes and the additional costs vendors and securities firms will have to bear to implement decimalization. Therefore, a phased approach for decimal implementation will be more cost effective and efficient.

Please let me know if you require any clarifications.

Sincerely.

Sara Banerjee
Vice President Data Operations & Procurement

Doug O' Hearen
Vice President Development

Telekurs Financial
3 Riverbend Center
Stamford CT 06907

Phone Number: 203-353-8100