Subject: File No. S7-02-10
From: Justin Hudock
Affiliation: Trader

June 28, 2010

In response to the Goldman Sachs comments I'd like to say a few words:

So the fox says to the hen: "Come on over and lay your head down on this chopping block, its the safest place for you."

I can't believe it took Goldman Sachs 17 pages to spell out the idea that: the market is perfect, we are making a truck load of money, don't change a thing. You could have summed up all your thoughts in one paragraph. I think 17 pages was a bit verbose for such a simple idea. Why didn't you just say we are here to talk our book.

I thought your section on HFT was especially void of any objectivity. I will quote here from page 9 of your response:
"Consequently, a broad range of investors and other market participants are now able to process
and trade on new market developments in a matter of sub-seconds. This increases efficiency by
facilitating the incorporation of newly available information into prices on a nearly instantaneous
basis. It also generally increases liquidity because investors and other market participants can
adjust their strategy more quickly as events take place, which reduces the risk of displaying

I'm going to pretend I'm one of George Bush's environmental lawyers and do a little red pen editing. When Goldman Sachs says "a broad range of investors" I think what they mean is "Goldman Sachs and a hand full of highly sophisticated firms with co-located algos" benefit from the speed of HFT.

And when Goldman says "investors and other market participants can adjust their strategy more quickly as events take place". I think again they are referring to themselves and the few other highly sophisticated firms. For they are talking about a time frame of .003 milliseconds or less. It takes .008 milliseconds to blink, so who else could they be referring to other then themselves. If Goldman Sachs actually know of investors who can change their mind, enter an order, and get a good execution in under .003 milliseconds, I'd love to meet the Flash Gordon.

When Goldman Sachs gives advice, RUN
(Unless its about how to loose a Billion in six months with sub prime CDO's)