Apr. 7, 2026
Ms. Vanessa Countryman Secretary, U.S. Securities and Exchange Commission Dear Ms. Countryman, I am submitting this comment regarding Proposal SR-NASDAQ-2026-009, which concerns the adoption of Rule IM-5101-4 by the Nasdaq Stock Market. After reviewing the details of the proposal, I wish to express my opposition in its current form, due to the significant expansion of delisting powers based on discretionary and unproven criteria, particularly when the concerning activity is caused by third parties unrelated to the issuing company. The proposal is based on observations of unusual trading in certain stocks, often resulting from social media campaigns aimed at artificially influencing prices. While these activities are concerning and must be addressed, the proposed mechanism focuses on punishing the outcome rather than addressing the root causes. Granting Nasdaq the authority to delist companies merely because their securities "may be susceptible to manipulation," even without any evidence of wrongdoing by the company or its management, raises several fundamental concerns: The proposal lacks clear, objective standards, relying on a broad and undefined set of factors, which could result in inconsistent and non-transparent decisions. It penalizes innocent companies and investors for the actions of external parties, potentially leading to significant market value losses, reduced liquidity, and weakened investor confidence. The proposal relies on SEC trading suspensions as a trigger for delisting actions that could be permanent, whereas the suspension itself is a temporary and time-limited measure, creating a regulatory gap. The proposal does not provide sufficient evidence that the issue is widespread or cannot be addressed through existing rules, such as ongoing listing requirements, liquidity, and disclosure obligations. Based on the above, I believe the proposal could have counterproductive effects by reducing the attractiveness of public markets—particularly for smaller companies—and increasing risks to investors rather than protecting them. Accordingly, I respectfully request that the Commission not approve the proposal in its current form, or at the very least, reconsider it to ensure: Clear and specific criteria for delisting decisions Requirement for tangible evidence of wrongdoing by the company Protection of investors from the effects of sudden delisting Focus on addressing manipulative third parties rather than punishing affected companies Thank you for providing the opportunity to submit this comment. I look forward to regulatory measures that strike a balance between combating market manipulation and protecting investors. Sincerely, Name: Asma Date: April 7, 2026 Email: [REDACTED]