Subject: File No. SR-NASDAQ-2006-040
From: Len Cereghino
Affiliation: The Cereghino Group

December 12, 2006

As an investor relations consulting firm, we have worked with many NASDAQ listed companies and with a host of service providers over the past 14 years. NASDAQ has offered a number of related services to listed companies as part of their listing fee. For instance the NASDAQ ownership and peer analysis feature is a tailored, private labeled targeting service that is also available to non-listed firms for a substantial fee, but is free for NASDAQ listed companies.

NASDAQs new program of offering additional bundled services appears to be an extension of their overall effort to extend the breadth and range of their offerings to their listing clients. As with many bundling efforts, Microsoft included, this action may reduce the number of firms that provide services to publicly held companies. It is unfortunate that they chose to introduce these new free services at the same time they instituted a rate increase. NASDAQ regularly raises fees, so the increase, which is relatively modest, should not come as a surprise.

As for the bundled services being proposed, we believe free introductory offers are an excellent way to evaluate new service providers. We have used Prime Zone, now Prime Newswires, for a few years and have always found their staff to be courteous, prompt and accurate. The Prime Newswire fee schedule is very competitive and from our limited experience their service ranks on par with their competitors.