Author: Steven Weil Date: 8/1/98 9:43 AM Subject: File No. 4-208;Comment on Proposed 34-40260;RIN3235-AH49;ITS For what it's worth, a blunt, bottom-line comment from a small investor: ITS appears to be nothing more than a cartel agreement for facilitating internalization of order flow and 'upstairs' type block trading. The criterion which I use for judging the ITS system is very simple: Is OptiMark a full participant? Yes or No.