Subject: File No. SR-ISE-2005-31
From: Kevin M Ryan

July 6, 2005

This is a comment strongly against SR-ISE-2005-31. This will put a lot of customers out of business as they will not be able to bear the burden of cancellation fees. Fees that to my knowledge do not exist in the all electronic world of S&P E-mini trading at the CME or in oil futures or eurodollar trading or any one of a host of electronic trading exchanges. This is simply the latest step in a war against sophisticated options traders who trade as retail customers. It should not be allowed. It is simply designed to put us out of business and takes away liquidity and improved markets from the options world. It takes away customers who make money trading options so that either ISE will make the money trading those options or make money from the cancellations. Either way it is a further corruption of free-market trading. It distorts the market by adding oppressive barriers to trade. These are dramatic increases in cancellation fees for the ISE options exchange. It is amazing that customers who enter orders that improve option markets and increase market liquidity will be punished for not getting fills. This is simply the end of free and fair trading for active retail customers. I beg for you not to approve this latest attempt to penalize the most active customers and endanger the continued growth of the industry, while letting the strongest option exchange call the shots for THEIR OWN benefit.