From: Tim Canning [tc@tclaws.com]
Sent: Monday, April 14, 2003 9:00 PM
To: rule-comments@sec.gov
Subject: SR-PCX-2003-13 (not on net)

To: Director; Division of Market Regulation

Re: Pacific Stock Exchange - Arbitration Rule changes (SR-PCX-2003-13)

I am an attorney in California, and a former arbitrator for the Pacific 
Exchange.  I currently represent 40 public investors who are residents of the 
State of California. These individuals have contracted with the Pacific  
Exchange (PCX) to arbitrate disputes that they have with PCX member firms.   The 
Exchange has unilaterally chosen not to honor those contracts.  

Late today, I received from the Exchange a copy of SR-PCX-2003-13.  I understand 
that the PCX has requested that that proposed rule change take effect 
immediately.    Because that proposed rule change will materially alter the 
contracts my clients have with the PCX,  I respectfully request that the staff 
of the Division permit ample time for comments on the "Proposed Rule" before it 
is declared effective.   Further, I note that the California rules and statutes 
to which the Exchange refers in its proposed rule change were enacted in July 
and late September, 2002, yet the Exchange has delayed six months before 
submitting its proposed  rule.  The proposed rule change is therefore not as 
urgent as the Exchange represents.

Thank you for your attention to this matter.



Sincerely,



Tim Canning



Cal State Bar No. 148336

350 E Street, Suite 201

PO Box 8019

Eureka, CA 95502



(707) 442-3064

fax: (707) 760-3523