Subject: SR-NASD-2003-158
From: Arnold Y. Steinberg, P.C.
Affiliation: Investors' Rights, Inc.

July 14, 2005

Dear Sirs:

I write to oppose any change in the Arbitration Code of the NASD that would permit Motions to Dismiss to be Granted by the Panel prior to an evidentiary hearing.

Investors find themselves constrained to the arbitration process because of efforts, on the part of the securities industry, to hold pre-dispute arbitration provisions in Customer Agreements enforceable.

Arbitration takes from investors many substantive and procedural rights that are otherwise available in state and federal courts. Permitting the summary dismissal of Statements of Claim would be one more unfair roadblock standing the way of victimized investors who seek redress for their losses.

Please do not permit any rules that further abrogate the rights of investors who participate in the securities arbitration process.

Arnold Y. Steinberg, P.C.
Attorney and Counselor at Law
Investors' Rights, Inc.
1420 Centre Avenue
Suite # 1504
Pittsburgh, PA 15219
(412) 434-1190
(412) 434-1131 (FAX)