Subject: File No. SR-NASDAQ-2006-040
From: Paul McBarron

December 12, 2006

The approach taken by NASDAQ to offer a bundled service to mitigate their fee increase is sensible and creative. Although our preference is for fees to be kept level we can see value in the bundled services approach. However, NASDAQ will need to offer an improved level of service e.g. distribution of press releases versus existing main competitor service providers. If they do not do so then they could be seen to be offering a theoretical bundled service as these will not be taken up by suscribers who in the end will suffer real higher fees.