From: George Rutherfurd
Sent: October 30, 2005
Subject: File No. SR-NYSE-2005-74

Dear SEC:

I have just become aware that the NYSE has submitted the above-referenced matter as an "interpreation" of Rule 108 for immediate effectiveness.

Per the requirements of SEC Rule 19b-4(f), the NYSE has not "properly designated" this matter as a rule interpretation eligible for immediate effectiveness.

Within the next several days I shall be submitting a detailed comment letter on this matter, which raises very serious issues indeed.

I urge the SEC staff not to process this matter until they have had an opportunity to review my comments.

Thank you for your consideration.

Very truly yours,

George Rutherfurd
Chicago, IL