"BOX represents a break from the traditional market model in which special trading rights are granted to the few in the hope that markets will be more orderly. In contrast to this view, the BOX enables all market participants to compete on a more level playing field. We support this view and believe that active and eager participation by the broadest possible set of investors is the best guaranty of deep and liquid markets. With a transparent trading model, all-electronic execution, lower costs, and minimal distinctions between trading participants, the BOX’s market model is a quite simply a better way to trade options."

"... the proposed price improvement period (PIP) mechanism proposed short duration is a protection for the party submitting the order against being free-rolled versus a market in motion.

The duration of the (PIP)mechanism is more than long enough for a full and complete price-discovery process to take place given the growth in automation of many trading firms. The propose (PIP) rules are a deterent, not an aid to internalization."

"As a potential market-maker for the BOX we are anxiously awaiting your approval of the format. It is our belief that this system will encourage price improvement on options orders which will benefit everyone, most notably the customer. Significant gains have been made in pricing options equitably and I believe this system will continue the progress."

"..it is extremely importantthat ..(BOX)...is being set up as a flat and open market structure, not as a "franchise" for specialists. Second, it's technology, price structure and qualifications for participation make it accessible to virtually all market makers which will ultimatlyprovide the greatest depth and liquidity. Third, the BOX will have a system which will be a competitive market in its truest form, using a strict price/time algorithm which will not and cannot discriminate between participants. "

"...enthusiastic supporter of this effort as of any effort to increase competition that will result in improved pricing and costs to the investing public. (BOX will).... be electronic, cost efficient, provide ease of entry to the order execution firms, and provide an alternative to the traditional establishments...(it is) very obvious that the primary beneficiary of the successful implementation would be the public. History clearly provides us with the evidence that increased competition coupled with transparency results in tighter spreads, deeper markets and greater liquidity. All of that should provide the customers- the public- with better executions and lower costs. "

"...are market makers on a number of derivatives exchanges around the world, including Amsterdam, London, Frankfurt, Sydney and Hong Kong... transparent, open, cost-efficient and competitive markets are in the best interest of customers, liquidity providers and order-flow providers alike..BOX supports these market characteristics.

BOX has very low entry barriers and a favorable fixed and variable cost structure for market makers. This will lead to increased competition and to smaller bid-ask spreads...full time priority rules (with the exception of the PIP) create strong incentive for market makers to improve bid-ask spreads... (ou) experience after the implementation of electronic markets in Europe has shown that the principle of time-priority combined with anonymity creates narrower bid-ask spreads. Also, we expect enhanced competition between liquidity providers on price, speed and technology, because no market participant will be in the structurally privileged position of specialist/DPM. All factors discussed above will decrease the implicit costs of trading for customers.

"I am an investor and retail options trade...I am interested in the best price when my order reaches a market, the lowest cost, best order routing and most importantly, the integrity of the price market. After reading Chapter V, Section 18 (of the BSE) rules that describe the Price Improvement Period, I perceive this model to be more beneficial to a public customer like myself than the current national best bid/best offer system."

"As a private investor with over 25 years options trading experience, I should like to express my view that the introduction of the BOX and its attendant rules would be a triumph for the small investor over the Wall Street powerhouse, and help level what is now a very uneven playing field. "

"We believe that BOX will bring to the options marketplace the best of all possible worlds, automation, low cost and transparency, coupled with price improvment. This most certainly leads to greater liquidity and tighter spreads. This ultimately benefits investors."

"(BOX's) electronic structure, low transaction costs, the display of the five best limits for each option, and low barriers to entry will only improve liquidity, transparency, and spreads in the US options market. The BOX model will bring many potential liquidity providers into the marketplace that do not want to manage the logistics of floor based market making and do not want to pay a large price of entry into an electronic marketplace."

"Ignoring consumers and preventing or crippling the BOX at the request of the existing options infrastructure and firms would be nothing more than legislating theft from my and other traders pockets into theirs."

"As a 13 year member of the CBOE I would like to voice my support for "BOX" as well as all platforms that provide transparent markets."

"As a current CBOE market maker and potential BOX participant, I would urge the SEC to move forward with its approval... This new exchange offers instant access to all levels of participants and market makers. It will have the obvious benefits of an electronic exchange, superior execution capabilities, yet it will not be the closed club the ISE is, where a limited number for market makers control the pricing. Flat and open with a large number of participants providing tight and deep markets. "

Professional trader

"As a professional and licensed trader for 25 years....I am in full agreement of the Price-improvement characteristics being suggested by the Boston Option Exchange. I traded an option on Upjohn on the first day the CBOE opened in 1973 (at the ripe old age of 20)

My trading in options in recent years has greatly diminished due to the egregious minimum spreads set by the various option exchanges. The BOX is attempting to greatly improve those prices. Should this proposed PIP take effect, I am certain that my option trading would increase by leaps and bounds (in quantity). "

"One noticeable improvement of the BOX over existing exchanges is that the membership structure is very open and cost effective, encouraging an unlimited number of liquidity providers to compete for our clients' business. More competition results in tighter spreads and deeper markets, both of which benefit our clients. Also, strict time priority, as opposed to existing Auto-Ex formats, encourage market makers to proactively improve markets as opposed to waiting for "their turn to trade." Once again, this will result in more competitive markets for our clients. The electronic format of the exchange ensures anonymity, eliminating the "crowd mentality" ...and the electronic platform will result in lower execution costs... creating opportunity to pass on savings to our clients. The quote request function will also allow me to seek out additional liquidity for large orders, once again increasing the chances of executing our client orders at more favorable prices. Finally, the ability of the BOX to provide market makers with a mechanism to honor a better market on another exchange will streamline my execution process, and will reduce the need to chase bids and offers on other exchanges.

In summary, the addition of the BOX as a new options marketplace will only help improve the quality of markets and executions in the options industry, and will help to eliminate many of the frustrations firms like ours have endured in recent years. Most importantly, the BOX appears to provide only benefits for our clients, and it is their interests that we need to protect."

"....strongly feels that the BOX will be an improvement over the current floor based exchanges... just by its open market structure, (BOX) will assist SSGM in providing for better quality executions for options trading. The unfettered and equal access to the order book that provides for strict time/price priority will allow all options trades to be executed at or better than the NBBO. This feature, in the current environment that involves a great focus on "best execution", will allow for greater execution quality of customer trades. The full automation that includes straight through processing of transactions and the minimal cost of entry will provide for lower executions costs and create the opportunity...to pass savings on to our customers. We believe the BOX platform offers the possibility of providing superior execution capabilities relative to other electronic exchanges (ISE). The greatest advantage of the BOX platform is more exposure to a greater number of market participants, which should, in turn, provide for greater opportunity for price improvement and liquidity. "

"BOX is a unique opportunity for customers, broker dealers, and market makers to receive fast, simple, cost effective and unrestricted access to execute their options business. BOX does not discriminate not does it discourage entry into the system. It in factencourages all participants regardless of what particular types of business they are looking to execute. All orders are live, and accessible to all participants. The multiple market maker system, encourages competition and will result in more liquidity, better prices and smaller spreads.

BOX features a unique mini-auction which will allow orders an opportunity to be price improved rather than executed at the NBBO as they are filled on other Exchanges. This mini-auction is fast and totally automated and will enable customer to receive improved prices.

This system will allow customers the opportunity for better prices at lower costs. Isn't that what it's all about? This is what the Commission should focus on and not how its competitors and opponents are trying to discourage a better way to do business."

"...strongly supports (BOX because)

Lower Cost of access: fully electronic... coupled with absence of a seat requirement will virtually eliminate typical barrier to entry for many smaller market makers...minimal fixed costs in conjunction with low cost of execution will attract new market makers and enhance competition, improving pricing for the public customer.

Faster Execution: ...faster executions, faster reporting of trades to all market participants... allows all participants the ability to better gauge their positions and will enhance market liquidity...eliminate unnecessary errors by reporting trades in a timely manner.

More Competitive Market: ...create a more competitive environment allowing greater access than any current exchange, electronic or open outcry. By attracting a great number of smaller market makers along with larger broker dealers and liquidity providers BOX will allow the same access for all levels of market participants...(and) lead to a robust trading environment that can only benefit the public customer by providing the most efficient pricing available.

In summation... the introduction of the BOX will dramatically improve the current options marketplace."