Date:    8/3/98
          6:37 PM
          
          Subject: Comments on File No. 4-208 (Optimark/PCX)
          
          I applaud the Commission for this proposal.  Although I have been critical in
          the past of U.S. government micromanagement of the securities industry, there
          are occasions when SEC action can improve competition and this is one of them.

          I support the proposal to provide the linkage of the Optimark system to the ITS
          through the PCX.  Optimark is a bold innovation in market design which should be
          allowed to undergo the market test without undue delay.   It should be allowed
          to compete on its own merits.

          I also do not see the need at this time for a  prophylactic formula to limit the
          fraction of Optimark activity that can be sent to the ITS system.  While I am
          sympathetic to the concern that a new trading system should not be a subterfuge
          to gain low cost access to the ITS system, it is quite apparent that there is a
          lot more to the Optimark system than an ITS interface.

          The proposed formulas are totally ad hoc and without any economic justification
          to show that exceeding the arbitrary numbers in the formulas would be contrary
          to the goals of the federal securities law. I believe that the Commission should
          monitor ITS usage and execution quality in the Optimark system after it
          commences operation and then decide if any further rule changes are necessary.
          The staff of the Commission is highly capable of examining this issue once it
          has the appropriate data to examine.  An arbitrary formula based on pure
          guesswork is a bad idea.

          Thank you for the opportunity to comment.

          Professor James J. Angel
          Associate Professor of Finance
          Georgetown University School of Business 
          Room G4 Old North
          Washington DC 20057