Subject: File No. SR-NASDAQ-2006-040
From: Bruce N Beckloff
Affiliation: VP of IR, ARM Holdings

December 8, 2006

In regards to the proposed fee structure and bundled services deriving from our NASDAQ listing, we view this as an improvement in the competitive environment and not detrimental in anyway. We use a variety of services from many providers (PR Newswire, Thomson Financial for example) and see no reason from what the NASDAQ is offering to change our relationship with those providers. We at ARM evaluate all services on an individual basis and each must provide superior value for ARM to engage. If anything, this will increase the competitive landscape and overcome complacency in offerings.