Subject: File No. SR-NASDAQ-2006-040
From: Efstathios D Gourdomichalis
Affiliation: CFO Freeseas

December 12, 2006

NASDAQs proposal, although increasing annual fees, enhances the competitiveness of listed companies. Most of the NASDAQ listed companies use these services anyway for a fee. If this proposal is approved, our company will be able to use such services valued at about USD 20,000, for free. In any case the fees will still be lower than those of the competitive markets. Finally, I find very compelling the fact that the adoption of the new fee structure would eliminate the entry fee for most companies transferring between the NASDAQ Capital Market and the NASDAQ Global Market.