Subject: File No. SR-NASDAQ-2006-040
From: Paul Richins
Affiliation: VP of IR, Utah Medical Products, Inc.

November 22, 2006

I believe this proposal is not in the best interest of public companies, including Utah Medical Products, Inc. because:
1) Higher overall costs. The proposed increase is more than 3x higher than we currently pay for the services we would get for "free" under the proposal.
2) Lower perceived quality. PrimeZone's reputation with news organizations is not on par with PRN or BW.
3) Less Competition. The proposal can only decrease competition - which inevitably leads to lower wealth for everyone.
4) Less Accountability. What incentive will Nasday have to provide exceptional service at the lowest price on the bundled services? No listed company will be able to demand high performance for a "free" service, particularly when it can't afford to get on the wrong side of Nasdaq.
5) Self Determination. Each company, not Nasdaq, can best decide how to meet its disclosure obligations.