Subject: File No. 4-602
From: John H Ray

September 14, 2010

In the best tradition of the SEC, please remember that a level playing field will yield the most efficient market, with the least corruption possible. Sub-pennying, for example, should either be available to everyone who would supply liquidity, or to none. Allowing only some players to sub-penny leads to abuse of the system. Though these players argue that their clients are better served, what about the customers of players who can't sub-penny? Are they better served? The SEC website declares, "The SEC protects investors by enforcing our nation's securities laws, taking action against wrongdoers, and overseeing our securities markets and firms to ensure that investors are treated fairly and honestly." How can sub-pennying (not to mention "flash trading") possible lead to investors being treated "fairly and honestly", unless all market participants are treated equally?

A level playing field is really just the minimum standard that the SEC should enforce. Come on guys, this is your country too. Give us a system that works for everyone fairly.