From: Feming1@aol.com Sent: Wednesday, December 31, 2003 9:07 AM To: rule-comments@sec.gov Subject: File No. S7-23-03 Feming Chan Trillium Trading 110 Fieldcrest Ave. Raritan Center 1 7th Floor Edison, NJ 08818 Mr. Jonathan G. Katz, Secretary Securities and Exchange Commission 450 Fifth Street, NW Washington, DC 20549-0609 Secretary Katz: I am writing to you regarding File No. S7-23-03 (Regulation SHO), the proposed short selling rule that is currently being commented on. As an active securities trader, I am concerned that Regulation SHO will not have the desired effect of creating a more fair market than the current short selling upbid rule does. I believe that when a trader or an investor bids on a stock, his main goal is to buy the stock at that price. It does not matter to him whether he is buying from a short seller or from a long seller. If he is concerned with getting an execution sooner, he would most likely prefer that the short seller have the option of selling him stock as well as the long seller. I believe that this will have the greatest negative effect on the small individual investor. Short selling is a part of a fair and equitable market. While Regulation SHO may help to prevent short selling to drive down a market, it also hinders short selling all together by making it impossible to short sell at the best consolidated bid. I believe that the proposed Regulation SHO will not aid in creating a more fair and equitable market than the current upbid short selling rule maintains. Sincerely, Feming Chan Securities Representative Trillium Trading