Subject: File No. SR-NYSE-2011-20
From: R. Jerry Falkner, CFA

May 22, 2011

It appears this rule would be highly anti-competitive in the Investor Relations industry by endorsing certain providers of IR and related services to the exclusion of the many smaller providers of such services that provide innovative and often-times better value to the shareholders of public companies.

I most strongly recommend that the SEC not approve the proposal to include the new Section 907.00 to the Listed Company Manual.