From: 	Paul M. Zislis[SMTP:PZISLIS@ACM.ORG]
Sent: 	Friday, November 14, 2003 8:44:14 PM
To: 	IMOCC@sec.gov
Subject: 	Comment on Proposed Rule Change
Auto forwarded by a Rule
 
I am writing in support of:
4-487 Sept. 30, 2003 Request for Rulemaking to Repeal a Proposed Rule
Change (SR-NASD-2003-52, Release No. 34-48279, 8/1/2003), which
allowed Nasdaq to Establish a Fee for Receipt of Mutual Fund Quotation
Service Data by Distributors.
Submitted by:   Robert C. Pelletier, President and CEO, Commodity
Systems Inc.

The proposed rule change (SR-NASD-2003-52, Release No. 34-48279,
8/1/2003) would result in unfair costs to individual investors like me
who subscribe to data services such as provided by Commodity Systems
Inc. The proposed rule would result in windfall income to the NASD to
which it should not be entitled.  Why should NASD be entitled to a
monthly fee from every 3rd party data distributor in a stream of 3rd
party data distributors?  NASD data is inadequate in itself and one of
the major reasons I subscribe to Commodity Systems Inc's data service
is in order to receive complete and accurate data in a timely fashion
- something I cannot receive directly from NASD. It seems clear to me
that NASD might reasonably collect a fee from whatever data services
use its data directly, but also charging every other party downstream
- those who pay another data provider already to receive data is
unfair and unreasonable. The result is bound to be to reduce
competition through loss of providers willing and able to bear the
added costs and to reduce the number of people like me who can afford
to subscribe to value added data providers such as Commodity Systems
Inc.

I strongly urge the SEC to repeal the proposed rule change
(SR-NASD-2003-52, Release No. 34-48279, 8/1/2003) as requested by
4-487.

Thank you,
Paul M. Zislis
216 Silverbell Court
West Chester, PA 19380
610-524-6972