Subject: File No. SR-ISE-2006-23
From: Michael Adams
Affiliation: President, KSMA Holdings LLC

June 22, 2006

The proposed rule changes are the latest in the ISE's attempt to discourage active trading on their exchange. The limitations they are trying to implement will reduce liquidity, price discovery, and lower volume. The main concern it would seem, is to ensure wider markets for their members. This not only does the exchange a disservice by lowering transactions, but also directly hurts the customer.

It is unreasonable to assume that any customer trading an active issue won't cancel many orders - imagine leaving orders in Google while the stock moves dollars in seconds. This rule will discourage cancelling these orders, or reducing a position in pieces so that the market makers can take advantage of the customer's limitations imposed by the new restrictions.

If the ISE truly wants to make itself a better competitor, it will strive to increase volume, increase transactions, increase liquidity and increase price discovery, and remove penalizing charges for those customers that are trying to add liquidity and volume to the market. This proposed rule change does the exact opposite.