May 27, 1998
     
     
     The following is a comment on the pilot for the revised Primary Market 
     Maker standards.
     
     Adams, Harkness & Hill, Inc. makes markets in 160 stocks with plans to 
     expand to two hundred.  As manager of the OTC department, I pride 
     myself in having very high Nasdaq ratings for volume per stock.  By 
     this measure, we were in the top 25 firms in 1997 despite a list that 
     included primarily small and mid-cap names.
     
     Our primary purpose in making markets is for the benefit of 
     institutional clients.  We are valued by them for our ability to 
     create  "naturals," often without benefit of having been on the bid or
     the ask in the process.  We pride ourselves in filling large orders 
     quietly without moving the market.
     
     Another constituency for us is our fellow dealers.  We recognize that 
     there would not be a Nasdaq market without them and so we participate 
     actively in intra-dealer trading.
     
     One constituency to which we attach a low priority is the professional 
     day trader, a.k.a. "SOES bandit."  We believe that participants in 
     this category serve to reduce the liquidity and increase the 
     volatility of the markets in which we are involved.  To the extent 
     that we can avoid trading with SOES, we do.  However, to the extent 
     that we move our market for a given stock without an intervening 
     trade, we score poorly on one criterion for primary market making. 
     Thus, it is unfair to use this criterion unless you have already 
     determined that the hyper-activity of the SOES system is a good thing 
     for the Nasdaq market as a whole.  And, you are well aware, opinion on 
     the value added by professional day traders is divided at best.
     
     In summary, we believe that the acid test for the "primary" 
     designation should be volume done in the name.  If a market maker is 
     doing the volume he or she is making a valued contribution to the 
     market place by definition.
     
     Sincerely,
     
     
     
     Benjamin A. Marsh
     Managing Director
     Adams, Harkness & Hill Inc.