Subject: File No. S7-21-09
From: Raghavan Guruswami, Ph.D

November 3, 2009

Flash orders go against transparent trading in a fair market place in a highly enabled environment. In the light of how few smart operators manipulated flash orders and what they have done to the markets, it is not a best practice anymore and hence, as rightly proposed by SEC, they are to be banned. SEC may also consider looking into the operations of these operators to find out whether they indulged in any rigging of the markets by placing the flash orders in the first place. Taking advantage of the quotes not publicly displayed is one thing and it could be viewed from non-transparency angle. Rigging the markets through flash orders is another thing and this should attract stiff higher penalties including debarment from future trading. I would request the SEC to look this, ban and investigate