Subject: Aspects of NASDAQ's SuperMontage system is unfair to individ
     
To whom it may concern:
     
I believe that the period for comments concerning NASDAQ's SuperMontage 
system recently expired.  My apologies for not submitting these concerns 
earlier -- I did not realize that the deadline was pressing.  I understand 
if you are unable to take these comments into consideration as a result of 
their tardiness.  However, the nature of my concern is a very general one 
that will apply to any subsequent online trading systems, so I do hope that 
you will consider them when making future regulatory decisions.
     
My main comment is this:  NASDAQ is allowing the market makers to keep 
secret more information that they are currently able to, and I would think 
that the trend should be just the opposite.
     
NASDAQ is proposing that SuperMontage will show consolidated bid and ask 
volumes to three increment deep.  They assert that this will give a better 
picture of the market to individual investors, making it more fair to them. 
I do not feel that this is so.  I see this proposed system as a step 
backwards from the current system.  I feel that SuperMontage will provide 
less information to the individual investor, giving an unfair advantage to 
Market Makers who have access to much more information about current supply 
and demand in a given stock.
     
While I can see NASDAQ's argument that more information will be provided 
because of the consolidated nature of the bid/ask information, the current 
system allows much more than three increment depth to be shown.  In 
addition, with the upcoming change to decimalization, each increment is 
going to become much smaller.  Under the current system investors are able 
to gage the supply and demand for a given stock up to several 1/16's, if not 
farther, away.  Under the new system, once decimalization goes fully into 
effect, we will only be able to see 3 cents away.  This effectively 
decreases the depth that individual investors can see by approximately a 
factor of 10.
     
NASDAQ acts as if this situation is not so problematic by saying that they 
will provide information on the 3 *OCCUPIED* bid and ask increments.  In 
other words, if there is no one at a bid 2 cents away from the inside, that 
will not count as one of the tiers and investors will be able to see 4 cents 
away from the market instead of 3 cents.  So?  That is still far too little 
information.  Indivudal investors are hamstrung compared to the market 
makers.  This does not seem just to me, and seems to be a step backwards 
from the current system.
     
I am very interested in what your opinion on this matter is.  A reply would 
be greatly appreciated.  I have included all my contact information below.
     
Sincerely,
James Ryley
14 Airway Circle, #2C
Towson, MD 21286
Phone: 800-888-6831 x101