Comments on NASDAQ Rulemaking

Notice of Filing of Proposed Rule Change to Modify the Listing Requirements Contained in Listing Rule 5635(d) to Change the Definition of Market Value for Purposes of the Shareholder Approval Rules and Eliminate the Requirement for Shareholder Approval of Issuances at a Price Less than Book Value but Greater than Market Value

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Date Received
Date Letter Type Commenter Name
Public Comment Nikolai Utochkin, Counsel, Listing and Governance, Nasdaq, Inc.
Public Comment Arnold Golub, Vice President and Deputy General Counsel, Nasdaq, Inc.
Public Comment Greg Rodgers, Latham Watkins
Public Comment Penny Somer-Greif, Chair, and Gregory T. Lawrence, Vice-Chair, Committee on Securities Law, Business Law Section, Maryland State Bar Association
Public Comment Michael A. Adelstein, Partner, Kelley Drye & Warren LLP

Last Reviewed or Updated: Dec. 18, 2025

File Number
SR-NASDAQ-2018-008
Release Number
34-82702
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