BOX-SR-BSE-2002-15From: sgibson@ScottStringfellow.com
Sent: Friday, September 05, 2003 11:01 AM
To: rule-comments@sec.gov
Subject: BOX-SR-BSE-2002-15

Dear Mr. Katz: 

In February of this year, I submitted comments supporting the approval of the 
Boston Option Exchange (BOX).  As the possible launch of this marketplace draws 
closer, I wanted to once again reinforce the reasons for our support.

As a former Options Market Maker on the Pacific Options Exchange, and now in my 
role as Option Strategist for Scott & Stringfellow, I have become disenchanted 
and frustrated with the structures and procedures of the existing floor-based 
exchanges.  These exchanges have failed to meet our simple expectations, which 
can be summarized as follows:

      a.. Fast execution and response times 
      b.. Executions at the best available price (NBBO) 
      c.. Time priority of orders 
      d.. Reasonable quote spreads with deep liquidity 
      e.. No "fading" of markets to avoid order execution 

I am confident the BOX will meet these expectations better than all of the 
existing floors, including the ISE.  One noticeable improvement of the BOX over 
existing exchanges is that the membership structure is very open and cost 
effective, encouraging an unlimited number of liquidity providers to compete 
for our clients' business.   More competition results in tighter spreads and 
deeper markets, both of which benefit our clients.  Also, strict time priority, 
as opposed to existing Auto-Ex formats, encourage market makers to proactively 
improve markets as opposed to waiting for "their turn to trade."  Once again, 
this will result in more competitive markets for our clients.  The electronic 
format of the exchange ensures anonymity, eliminating the "crowd mentality" that 
I am all too familiar with having been in a crowd myself.  Also, the electronic 
platform will result in lower execution costs for Scott & Stringfellow, creating 
opportunity to pass on savings to our clients.  The quote request function will 
also allow me to seek out additional liquidity for large orders, once again 
increasing the chances of executing our client orders at more favorable prices.  
Finally, the ability of the BOX to provide market makers with a mechanism to honor 
a better market on another exchange will streamline my execution process, and will 
reduce the need to chase bids and offers on other exchanges.

In summary, the addition of the BOX as a new options marketplace will only help 
improve the quality of markets and executions in the options industry, and will 
help to eliminate many of the frustrations firms like ours have endured in recent 
years.  Most importantly, the BOX appears to provide only benefits for our clients, 
and it is their interests that we need to protect.




Shawn Gibson 
Senior Vice President 
Equity Derivatives 
Scott & Stringfellow 
(804) 782-8709 
sgibson@scottstringfellow.com