Wilson-Davis & Co. Inc. 39 West Market Street Suite 300 Salt Lake City, Utah 84101 (801) 532-1313 April 29, 1998 Jonathan G. Katz, Secretary The Securities and Exchange Commission 450 Fifth Street, NW Washington, DC 20549 Re: File number SR-NASD-98-21 NASDAQ Proposed "Actual Size Rule" (Sent via E-mail and follow-up letter) Sirs: We wish to comment on the proposed rule. The time has come for the implementation of the rule. In today's environment of high speed electronics, the artificial minimum size is unfair, gives opportunities for "bandits" to take advantage, and is detrimental to the market place. We have experienced being hit with trades faster than we can update our quote. When the computer is receiving, it cannot be used to transmit outgoing. Thus in a fast market there are moments when the send keys are delayed, even for a fraction of a second, when updating is prevented and orders are coming through hitting the present quote and in a size that is unfair. Other exchanges and Electronic Communications Networks (ECNs) are not forced to these same artificially high minimum sizes. If the rule were adopted, fairness between trading locations would result. Respectfully, Lyle W. Davis, Wilson-Davis & Co. Inc. Secretary/Treasurer