Subject: File No. JOBS Act Title I
From: Ernest Callipari
Affiliation: Equity Trader

August 14, 2012

I believe a pilot program increasing the MPV's in a select group of "growth companies" is the only way to answer all the questions proposed in the SEC's Tick Study. I believe with a greater tick spread we will see an increase in market makers in any stock trading in more than penny increments because wider spreads makes market making profitable. Any entity willing to risk capital making markets should be rewarded with a reasonable return for risk. In turn you will see more depth and liquidity in these socks which will in turn attract more investors and traders into these stocks which will again increase depth and liquidity and in the long run strengthen the stock thus the companies the stocks represent.
It was never proven that the "optimal price spread" was a penny when the markets went to decimalization. The penny spread also had an unforseen and dire consequence: the rise of the algo and the death of the human trading element. Today's market is no more than predatory algo's feeding off each other. I believe you are now seeing the results of the penny spread's effect on depth, liquidity and stock price of IPO's. Just take a look at Facebook, Zynga, Groupon, etc. In this market climate and structure, why would any company go public?