Subject: File No. S7-02-10
From: William Silver
Affiliation: Investment Manager

May 20, 2010

The proposed circuit breakers will not eliminate abberant trades unless they prevent a trade from being executed outside of the 5 minute allowable parpameters. The recent market event was characterized by large gap trades, many of which, this system would not avoid.

Activating the circuit breaker AFTER the parameters have been breached is not the way to go. You must be able to block an execution at a price change that you were trying to avoid.

William Silver