From: Saeyoon Kim [saeyoonkim@hotmail.com]
Sent: Thursday, January 01, 2004 10:13 PM
To: Rule-comments@sec.gov
Subject: File No. S7-23-03 

						140 west End Ave. #17E
						New York, N.Y. 10023


Mr. Jonathan G. Katz
Securities and Exchange Commission
450 Fifth Street, NW
Washington, DC, 20549-0609


Dear Mr. Katz,

I, Saeyoon Kim, am a registered representative at Trillium Trading and I am 
writing to you in regards to the new Regulation SHO(File No. S7-23-03). I 
have six years of experiences as a registered representative, and I feel 
that the proposed rule change would threaten the fair marketplace.

In my understanding, if there is an ¡°up arrow,¡± there is no restriction of 
a short sale that may be executed. Since ¡°up arrow¡± definitely creates a 
higher inside bid than previous due to a real buyer who is willing to buy at 
the higher price.  With Regulation SHO, the price at which a short sale can 
be executed will be one cent above the best bid.  This proposed rule change 
would diminish fairness in the marketplace.  Every bid and offer should 
represent real intensions of investors and traders. However, this proposed 
rule change would wrongfully create a loophole of denying investor¡¯s right 
to sell the stock to a buyer agreeing to the price. Taking away this ability 
of fair market trade will do more harm than good for the small investor.

Another reason why I strongly oppose the proposed rule change is that Market 
Makers are exempt to the rule change. It¡¯s detrimental enough that they 
already have the advantage to short on a down tick and remain anonymous 
while using the SIZE symbol.   I have seen that Market Makers manipulate a 
stock while constantly shorting on a down tick.  It is already bad enough 
Market Makers have unfair advantage over the small investor and this 
proposed rule change will only widen the gap between them.

I believe the true meaning of ¡°fair marketplace¡± can be preserved if all 
the participants of the marketplace are treated under fair and transparent 
conditions. Therefore, this proposed rule change will be harmful to all the 
investors and the fairness of the marketplace. Thank you very much for your 
time.



Sincerely,


Saetoon Kim

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