Mr. Jonathon G. Katz
Secretary
Securities and Exchange Commission
Division of Market Regulation
450 Fifth Street, N. W.
Washington, D.C. 20549


Dear Mr. Katz:

In response to the SEC's request for comments on SR-NASD-95-42.
NAqcess Limit Order file 

Do I understand correctly... that a customer cannot enter a limit order
for a NMS stock quoted over 10 at 10 5/16? That the limit order price 
must be => 1/8? If the foregoing is correct, then it is a giant step 
backward. If two customers agree electronically to buy and sell at 
10 5/16 why shouldn't the trade cross? SelectNet today will accept 
10 5/16?

The "firm quote rule" is an evolutionary rule that exists in in all
markets. No dealer will last in the securities business if his
quote is only "good-'til-close". NAqcess, as proposed, will allow
the dealer to think about whether to execute at his quote for 20
seconds...whether he has contemporaneously executed an order or
not. If he has not executed an order and decides not to abide by
his quote then he is guilty of "backing away" and should be
punished. The record of the NASD punishing dealers for "backing
away" needs to be examined. To allow the dealer to decide whether
to honor his quote also allows him to discriminate. If the dealer
bid is for 1000 shares of ABCD at 10 1/2 and he gets a an offer at
10 1/2 for 300 shares and decides to wait the 20 seconds and, in
the meantime, gets an A-O-N offer for 1000 shares at 10 1/2. Does
he execute the second order immediately and decline the first
order... because he has "contemporaneously" executed the second
order? If this is a violation, how will he be caught and punished?
Further, if the dealers collectively by policy, habit, or otherwise
all practice a 20 second wait period before executing, won't this
hurt the market efficiency? Reduce liquidity? Discourage the
public?

Solution. The current SOES mechanism works just fine. Incorporate
the current SOES rules into NAqcess.

Sincerely,

Robert P. Ross, Jr.
President
GRO Corporation
3000 Weslayan Street
Suite 390
Houston, Texas 77027
1-713-439-1727