From: John Davidson [jdavidson2003@hotmail.com]
Sent: Wednesday, September 03, 2003 8:13 AM
To: rule-comments@sec.gov
Subject: SR-BSE-2002-15 (BSE Form 19b-4, Amendments)


Under the new BOX rules, Customers will now be able to participate in the 
PIP process (CPO).  However, other PRO traders (B/D ordes) will NOT be able 
to particiapte in PIP.  See Chapter V. Section 18(g).

Just as customers complained re the BOX's first proposal (JAN 2003) about 
this inability to access PIP, PRO traders should also complain about the 
current proposal.

The fact that one has the best bid/ask will not insure PRO traders of 
priority if PIP takes place.  In such cases the PRO trader could be the best 
bid (with time priority) all day for an option (with a BOX Market Maker) and 
never get a fill because PIP's are constantly taking place .01 higher.  And 
the PRO will not have the ability to trade in such increments.

Recently, Option Exchanges have begun treating all orders the same (B/D and 
customer).  I believe that if the BOX really cares about fair access to all 
participants then they will also allow B/D's to enter similar type CPO's 
(customer PIP orders).


STL

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