From: Earle A. MacKenzie
To: Securities and Exchange Commission
Shenandoah Telecommunications Company requests the SEC disallow the fee structure proposed by NASDAQ for 2006. The new structure bundles certain services such as press releases, webcasting and EDGAR services into the fee. The fees should only represent the core functions NASDAQ performs. Their proposal is particularly unfair to smaller companies that do not have a reasonable alternative to NASDAQ.
Shenandoah does not object to NASDAQ offering these services, but they should be optional and the 2006 fee should exclude these additional services. For example, Shenandoah does not use webcasting to communicate to our shareholders and therefore we do not think it is fair to be required to pay for a service that we do not intend to use. The current proposal requires companies listed on NASDAQ to either use the services included in the fees proposed by NASDAQ or pay twice for the same service.
The companies listed on NASDAQ and the public will be best served by open competition and transparency of prices in an unbundled optional NASDAQ fee structure.
Earle A. MacKenzie