From: Shannon H. Burns, CFA
I am opposed to allowing Nasdaq to attempt to justify an increase in rates by bundling services that listing companies may have no desire or intention to use. Our company has a long-standing relationship with another newswire, and I am resent being forced to either alter that relationship or pay twice for the same service. This argument also applies to the Edgarization services that are being bundled. As to the HTML conversion of our annual report, we have chosen not to do that because of the cost involved; I do not want Nasdaq making my budget decisions for me.
It appears that Nasdaq is using what is close to a monopoly position to force listing companies to pay for services from businesses that Nasdaq has acquired to expand its business model. If Nasdaq wishes to enter other businesses, it should compete on a level playing field. It should not have the ability to force small companies to pay for services they do not want or use providers they do not prefer because of Nasdaq’s essential monopoly.
I request that the SEC deny Nasdaq’s request for a rate increase based on the additional services.
Shannon H. Burns, CFA