From: james whitticom [jameswhitticom@yahoo.com]
Sent: Wednesday, December 31, 2003 1:33 PM
To: rule-comments@sec.gov
Subject: RE: File No. S7-23-03


December 22, 2003


Mr. Jonathan G. Katz
Securities and Exchange Commission
450Fifth Street, NW
Washington, DC 20549-0609


RE: File No. S7-23-03


Dear Mr. Katz:

   I have been a professional trader for eight years. 
I am currently a registered principal at Trillium
Trading LLC in Boston Massachusetts.  I am writing to
you to explain my opposition to proposed Regulation
SHO.

   A new uniform bid test allowing short sales to be
effected at a price one cent above the consolidated
best bid would dramatically decrease liquidity on the
NASDAQ exchange. The smooth and orderly functioning of
day to day trading on NASDAQ depends on an environment
where buyers and sellers are able to match at a price
acceptable to both parties.  By instituting a uniform
bid test allowing short sales to be effected at a
price one cent above the consolidated best bid NASDAQ
would not only be making short selling more difficult
in any given security (and decreasing liquidity) it
would also be making buying any security much more
competitive.  With a lack of short sellers selling at
the bid, any individual investor wanting to purchase a
security would have no choice but to pay the offer in
many instances.  This spread can be a significant
amount of money and discourage many investors from
buying a particular security on any exchange with such
a rule.

   Proposed Regulation SHO would be a serious error. 
It would decrease market liquidity, force individual
investors to pay higher premiums, and create a very
inefficient marketplace where buyers and sellers could
not meet a price where both would like to do business.

   I thank you for taking the time to listen to my
concerns. 

Sincerely,

James Whitticom


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