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Exhibit 10.10
No
Action Letter Issued by Securities Exchange Commission dated
January 6, 2005 to operate Track ECN through October 6, 2005
Robert P. Bramnik
Duane Morris
227 West Monroe St.
Chicago, IL 60606
Re: Track System
This letter
extends the temporary no-action position originally taken by the
Division of Market Regulation ("Division") on January 7, 2002 until
October 6, 2005. This letter also extends the no-action position
taken by the Division on May 30, 2003, relating to exchange-listed
securities. In the January 7th and May30th letters, you confirmed
the Track ECN ("Track System" or "System") operated by Track Data
Securities Corp. ("Track") is an "electronic communications
network" ("ECN") as defined in the amendments to the Quote Rule and
the Limit Order Display Rule (Collectively, "Order Execution
Rules"). You also confirmed that the Track System would be in
compliance with the requirements of Rule 11Ac1-1(c)(5)(ii) of the
Exchange Act ("ECN Display Alternative") with respect to any Nasdaq
and exchange-listed securities for which a linkage between the
Track System and the self-regulatory organization ("SRO") is
operational. In the January 7th and May 30th letters, the Division
took the position that it would not recommend that the Commission
take enforcement action against any OTC market maker or exchange
market maker as defined in the Order Execution Rules, for entry of
orders into the Track System without modifying their public
quotations in compliance with the ECN Amendment.
The
Division continues to condition its position on compliance w
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