From: Bill Perry
Sent: November 28, 2006
Subject: File No. SR-NASDAQ-2006-040

To whom it may concern:

I’m against NASDAQ’s proposed rule change. I urge the SEC to disapprove (or amend) the rule in question, so Nasdaq-listed companies do not have to pay twice to distribute news releases via wire services. If the rule stands as is, my company will pay once for news distribution services via NASDAQ’s relationship with PrimeZone. And we’ll pay again to distribute our news via services such as PRNewswire and BusinessWire, which most media outlets recognize.

Bill Perry
Director, Public & Investor Relations
SumTotal Systems (Nasdaq: SUMT)