MessageFrom: George Papa [gpapa@peak6.com]
Sent: Monday, February 10, 2003 5:07 PM
To: rule-comments@sec.gov; roeserj@sec.gov
Cc: Matt Hulsizer; Jenny Makowiec; Danny Rosenthal; JP Just
Subject: SR-BSE-2002-15

 
TO:  
Mr. Jonathan G. Katz, Secretary
Securities and Exchange Commission
 
FROM:
Mr. George Papa, Director
PEAK6 Investments
 
RE: 
SR-BSE-2002-15, Boston Stock Exchange, Inc. Filing to Establish Trading Rules 
for the Boston Options Exchange Facility.
 

INTRODUCTION 

PEAK6 is a proprietary options market making and trading firm which routinely 
takes option postions and commits capital in the exchange listed options 
marketplace.  PEAK6 currently has no affiliation with BOX or the Boston Stock 
Exchange.  If approved, PEAK6 does intend to become a member of the BOX and 
participate fully in BOX markets. 

COMMENTS 

PEAK6 supports approval of the BOX submission and believes that the creation 
of an additional, fully automated, options exchange will enhance the competitive 
landscape within the options industry.  In particular, PEAK6 believes that the 
creation of an options exchange with an open market structure that enables and 
encourages transparency represents a substantial improvement in the competive 
landscape of the exchange traded equity options marketplace and is both 
consistent with and suggested by the sound principles that have guided past 
SEC actions. 

Further, PEAK6 believes that that best way to achieve a true open and competitive 
equity options marketplace is through the employment of automation technology 
capable of reducing the effective time required to "interact" with the marketplace 
to a minimum established by extant technology limits rather than mandated by the 
requirements of human-hand order handling.  Further, PEAK6 recognizes that the 
utilization of automation technology is a requirement for the effective remote 
or off-floor market making activities anticipated by the BOX proposal.   

Also, PEAK6 believes that the proposed price improvement period (PIP) mechanism 
represents a significant competitive improvement when compared with current 
customer order handling practices.  Further, PEAK6 represents that it is both 
capable of, and interested in, participating in the short duration automated 
price improvement auction as described.