Author:  Steven Weil 
          Date:    8/7/98  3:55 PM
          
          Subject: Revision of ITS Plan/Optimark System; File No.4-208: Propose

         
          Attention Mr. Jonathan G. Katz:

          Thank you for the opportunity to comment on the proposed ITS Plan Revision.

          As a small investor and member of the public, I am directly affected by any
          revision of the ITS Plan which would permit the Optimark System to commence
          operation.  This change in the ITS Plan would allow my small retail orders to
          interact directly and annonymously with large institutional orders. I commend
          the Commission for actively expediting the approval process for this Revision of
          the ITS Plan.

          At the present time, the Proposed Revision can not be implemented. Despite the
          fact that the majority of Plan Members voted in favor of it, a minority which
          was opposed to revision, vetoed it on the basis of a minor technicality. This
          investor commends the Commission for promptly taking steps to keep the approval
          process on track.

          The Commission cited two recent major precedents in which it was necessary for
          them to over-ride vetos to revisions of the ITS Plan. The current PCX/Optimark
          instance, differs from the prior instances in one major respect: The Optimark
          System would allow small retail orders to directly and anonymously interact with
          large institutional orders. It would improve public access to the National
          Market System. This is sufficient grounds for over-riding a purely parochial
          veto.

          Not being a Plan Member, I will not comment on the minor points in contention.
          Instead I will simply restate  the over-riding issue: Should New York
          Specialists be allowed to prohibit the implementation of a significant
          technological innovation, namely the OptiMark System, in order to preserve
          traditional special privileges which are, in part, based on the artifical
          maintainance of market inefficiencies. In other words, what is at issue, is the
          nature and purpose of the National Market System. It is the responsibility of
          the Commission to be the ultimate arbiter of these issues. And again I commend
          the Commission on its willingness to encourage technological innovation such as
          the OptiMark System.