From: Geoffrey M. Boyd
Sent: December 4, 2006
To: rule-comments@sec.gov
Subject: SR-NASDAQ-2006-040

Dear Sirs:

I am strongly opposed to any increase in NASDAQ listing fees related to NASDAQ's acquisition of PrimeZone (now known as PrimeNewswire). It has come to my attention that NASDAQ is using this acquisition as a justification for increasing annual listing fees for its members by as much as $20,000.

We are very satisfied with our current news wire service and do not see any benefit to having news wire services bundled with our NASDAQ listing. In fact, we will be paying double for news wire services with the proposed changes because we have no intention of switching news wire providers from our current provider.

Please reject any component of NASDAQ's listing fee increase that is in any way related to news wire services and/or NASDAQ's acquisition of PrimeZone.

Thank you.

Sincerely,

Geoffrey M. Boyd
Chief Financial Officer
Eschelon Telecom, Inc. (ticker "ESCH")