Subject: File No. S7-02-10
From: Klaus Johanns

April 14, 2010


This is to address the unfair inequitable advantage the broker dealers have over John Q public via Sub-Pennying. They are able to step in front of displayed orders allowing them - broker-dealers to profit very handsomely by "playing inside the spread" taking advantage of the investors.

Its only fair to standardize the playing field make it fair for all parties to have a level playing field and not allow one group to benefit by being able to do something no one else can do. STOP THE SUB-PENNYING