August 31, 1998 Jonathan G. Katz, Secretary Securities and Exchange Commission Re: file #4-208 Dear Mr. Katz: I have just returned from Europe and perhaps am too late for commenting on the proposed amendment to the National Market System Plan which you requested be submitted by August 21st, however, hopefully you will bear with me. Approximately twenty years ago I enjoyed representing the Pacific Stock Exchange when we were laying the foundations of a National Market System. I was President of the Pacific Clearing Corp.(PCC) and Senior Vice-President of the Pacific Stock Exchange (PCX) from 1973-80. We established the first ever trade clearing interface system between the PCC, and the then NOTC. Subsequent clearing interfaces with ASECC/SCC now NSCC etc, and the simultaneous interfacing of our depositorys established a national system of clearance and settlement that enabled broker dealers to have one net account in which they could clear all their transactions regardless of the marketplace in which it was executed. With this system in place we were then able to establish the ITS (Intermarket Trading System). I had the pleasure of working on the foundation committee representing the Pacific Exchange. This established the basis of a National Market System (NMS), enabling for the first time the stock exchange specialists to readily access each other's markets. To my understanding there has been little advancement in the NMS since the major step of establishing ITS. The automated order routing and trade executions of the exchanges I am sure have been enhanced and interaction with the OTC markets has been expanded. Brokerage firms have developed Internet access etc., but the basic NMS trading systems have not changed. I was most dismayed to read that the New York Stock Exchange, again trying to protect their monopolistic role in our industry, was objecting to and suggesting deterrents regarding the Pacific Stock Exchange expansion of its automated executions by linking with the "Optimark" trading system. I would hope that the Securities Exchange Commission is overseeing the development of a NMS as mandated by the 1975 revisions of the 1933/34 Securities Act. The NMS should provide the investing public with the ability to trade risk for capital in the most efficient and honest fashion. The more integrity in our NMS system the more it will be trusted by investors world wide in our ever growing global economy. We need to improve the NMS at any opportunity. The PCX with "Optimark" technology will be a major step in the right direction. The customer's complete anonymity can be trusted in this system. It should virtually eliminate the scourge of our industry's order front-running and other hard to police execution irregularities. There are other technical advantages as I am sure you are aware in the "Optimark" system, and the sooner we implement this operation the better. The NYSE objections are unjustified and purely a lame attempt to stop their old walls from falling down. In fact the SEC should help kick them down and provide the investing public with a truly automated NMS. It has only been twenty years! Respectfully, _______________________________ Barry Blackmore 130 So. San Rafael Pasadena, CA 91105 (626) 792-7130