wise ...
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Indeed there is dilution And I'm very upset about it ..
Too bad you are not coming, I will miss you there )
Trader let's say dec 2008 for an appropriate value ...
let's add some facts together . Shall we ?
1 Deal with SFB and meeting June 11th
2 The day after it's shareholder meeting ! Coincidence
3 This deal will save Millions to the industry
4 Exposure will be in Stratosphere very soon
5 Spzi Share price doesn't belong In this range at all ... and you are going to find out the 12th of this month ...
Rock you post 15 times a day ! and I still need clarification from you
your statement in the Spooz story while factually incorrect, may be subject to a misunderstanding or unfair assumption.
Rock can you rephrase in a more intelligible fashion , I didn't understand your point Thank you ..
Rock you have failed to convince me , The more you bash this Company the more shares I'm buying .. Your strategy at least doesn't work on me ...
Rock what kind of solid revenues are you bringing here to this board If I may ask ..?
Pretty decent list of questions, It's in the favor of Paul to reply to all questions and open the gate for new investors to Join . Great job IT
IT guy To add to your 10 pertinent questions , I will like to see a revised
Revenue projection for 2008 and 2009 in regard to all new developments
Thank you very much
Rock time to Count 11 more posts for you today ,let's talk about
1 Dilution
2 reply to IW
3 posting from 2006
4 the failure of Communication of SPZI
and what else today ? Please let us know ..
SFB Market Systems
800 Jessup Rd., Suite 802, Thorofare, NJ 08086 – 856‐853‐1800
September 25, 2007
Ms. Nancy M. Morris
Secretary
Securities and Exchange Commission
100 F St. NE
Washington DC 20549
Re: Comment Letter re: SEC Release No. 34‐56037 and Submission of Proposed National
Market System Plan for Reserving, Selecting and Allocating Securities Symbols Pursuant to rule
608; Rules 533 and 534
Dear Ms. Morris and SEC Members,
Per our conversation with and at the suggestion of David Liu of the SEC, this letter is being written in
response to the above mentioned filings. Pursuant to Section III of Amendment No. 1 to the Symbology
plan (File No. 4‐534) and NMS plan for the Selection and Reservation of Securities Symbols, Section III
in both plans reads as follows:
III. Performance of Functions
As determined by its Policy Committee, ISRA will be delegating the operation of the Symbol
Reservation System to an independent third party (the “Processor”), and will enter into contracts
with such party describing the functions to be performed by it and the service levels and other
terms related thereto. The Processor shall be required to agree that any nonpublic information
that becomes known to it shall be held in confidence, except as it may be shared with the
Commission or other appropriate governmental regulatory authorities or as otherwise required
by applicable law.
Based on the requirements requested by the industry and in response to the proposed National Market
System (NMS) plans for the selection and reservation of securities symbols, The Symbol Management
Clearing Corporation (SMCC) was established in August of 2007. SMCC is committed to functioning as
the independent third party (the “Processor” and “Symbol Master”) and providing the trading industry
with more accurate symbology.
There have been two of these plans filed with the SEC to date (one sponsored by NASDAQ, NASD, NSX
and PHLX, and the other sponsored by AMEX, NYSE and NYSE Euronext; NMS File No. 4‐533 and 4‐534
respectively). SMCC is an independent organization functioning with the interest of the publicly‐traded
Original 2004 Document: by SFB Market Systems Inc.
companies. For the past twelve (12) years, the options exchanges have been managing symbols with
the SFB product Symbol Manager which is now integrated into the central repository server known as
Symbol Master, another SFB Product. In addition, the SMCC is fully prepared to continue this
management process with the SFB technology and services currently in place in all of the U.S. options
exchanges.
Also, attached are the original exchange “Base‐Line Rules and Guidelines” originally written by SFB in
December of 2004, at the request of the industry to fulfill the requirements of the Symbol Reservation
System particularly in the area of options symbology but not limited to options.
The SMCC is the only independent, third party processor qualified and experienced to perform the
duties of the symbology management provider for the securities industries.
We appreciate your time and commitment to the trading industry by overseeing the services that will
enhance both the exchanges and our economy. If you have any questions or comments, please do not
hesitate to contact me directly.
Sincerely yours,
S. Lee Clifford
President and CEO
cc: Erik R. Sirri, Market Regulation, SEC
Elizabeth King, Market Regulation, SEC
David Liu, Market Regulation, SEC
Neal L. Wolkoff, Chairman & CEO, AMEX
Michael Bickford, Sr. Vice President, AMEX
Michael J. Curran, Chairman & CEO, BSE
Edward J. Joyce, President & COO, CBOE
David A. Herron, CEO, CHX
David Krell, President & CEO, ISE
Steve Joachim, Executive Vice President, NASD
William O’Brien, Senior Vice President, NASDAQ
James C. Yong, Chief Regulator Officer, NSX
Noreen M. Culhane, Executive Vice President, NYSE
Marsh N. Carter, Deputy Chairman, NYSE Euronext
Catherine R. Kinney, President and Co‐COO, NYSE Euronext
Pamela Zielezinski, Sr. Vice President, NYSE Euronext
Scott M. Donnini, First Vice President, PHLX
Original 2004 Document: by SFB Market Systems Inc.
Symbol Reservation System
The Original Exchange Base‐Line Rules/Guidelines
Original ‐December, 2004, By: SFB Market Systems For:
The Symbol Management Clearing Corporation (SMCC)
The Symbol Management Clearing Corporation is a symbol repository data management corporation designed to
collect and protect the confidentiality of information submitted about the past, current and future ownership of
symbols that represent companies traded on the Equity and Option exchanges. (But not limited to equities and
options)
Exchanges submit their symbols, determine symbol availability, request the acquisition of available symbols,
transfer symbols, deny or accept a transaction offered by another exchange, communicate appropriately,
anonymously and confidentially with other exchanges about symbols.
A. Symbol Reserve Exchange List:
• PCX Pacific Exchange
• ARCA Archipelago Exchange
• ISE International Securities Exchange
• AMEX American Stock Exchange
• BSE Boston Stock Exchange
• BOX Boston Options Exchange
• CBOE Chicago Board Options Exchange
• CHX Chicago Stock Exchange
• PHLX Philadelphia Stock Exchange
• NYSE New York Stock Exchange
• NTX National Stock Exchange/Cincinnati Exchange
B. Initial Load / Setup of the “Online Symbol Master / Repository”
B1. Initial Loading “Exchange Symbols on Reserve”
a. Each exchange will supply a list (file) of symbols believed to be on reserve by their own exchange.
If your list (file) contains other exchange symbol reserve information, these symbols will be used
to load the database of the non‐participating exchange.
b. Symbols being loaded on behalf of a non‐participating exchange will be placed on reserve based
on what another exchange thinks the non‐participating exchange has on reserve. However, a
non‐participating exchange is urged to submit their own list (file) to establish solid ownership of
a non‐active symbol prior to it being placed in the open list.
c. Symbols not listed on any of the exchange lists (files) will be placed in the unreserved open
database and will be available for transfer.
d. Symbol List (file) fields required from each exchange:
• Symbol – Symbols listed as reserved by your exchange will be loaded into your exchange
database. All other symbols will be analyzed and assigned according to the rules stated
above.
Original 2004 Document: by SFB Market Systems Inc.
• Date Reserved – date your exchange reserved the symbol ‐if an invalid date is received
– a date of 01/01/2004 (back dated 1 year) will be established.
• Comments (Optional)
e. Active / Inactive Symbols – All symbols will be checked for an active and inactive status.
If a symbol is deemed inactive it will be date time‐stamped with 02/06/2005 to begin the six‐
month inactive clock.
B2. Initial Symbol Load Discrepancies / Contested Symbols
a. Symbols will be listed as a Contested symbol if more than one exchange has claimed ownership
of the same symbol.
b. If the symbol is contested by another exchange, a “Request to Resolve” the dispute will be
submitted to SMCC acting only as the mediator. Both exchanges must supply documentation
showing the earliest reserve date on record and/or correspondence showing a transfer of
ownership rights.
c. If an exchange is involved in a contested symbol dispute and elects to be removed from a
contested state, the exchange may do so automatically online using the “Release Symbol to
Exchange”. User must be an authorized Level 2 user from the exchange requesting the release of
the contested symbol.
B3. Initial “User Profile” Setup
a. Each exchange will be provided with 2 user profiles unless a request for additional users has
been arranged through SMCC. Users can be of the following status/levels:
Level 1 – User / Read Only no transfer capabilities
Level 2 ‐ Manager – Transfer Authority
Level 3 ‐ Exchange Administrator – Transfer Authority and Manage Users
b. User Information Required Maintained on file:
• User First Name
• User Last Name
• User Phone # and Ext.
• User email address
• Email Notification List – email address of the person to be copied on all transfer
related correspondence for your exchange.
• UserID – All UserID’s will be established by SMCC
• Password – Your initial password will be randomly generated and emailed to the
email address you provided in your user profile.
C. Unreserved Symbol Repository:
Definition: “Unreserved Symbol Repository” – Any symbol NOT “Active” Not on “Reserve” and NOT “Exempt” by
another exchange. All unreserved symbols are listed in the “Open List” of symbols.
C1. Requesting a symbol from the “Unreserved Symbol Repository”
a. User may select any symbol from the “Open List”.
Original 2004 Document: by SFB Market Systems Inc.
b. Symbol is time‐stamped at the time of request and will be assigned to the Exchange on a first‐
come‐first‐serve basis.
c. If a symbol request is terminated or cancelled for any reason the symbol is returned to the “Open
List”.
d. Any Exchange with more than 1,000 symbols on reserve must give a symbol to the “Open List” in
exchange for the requested unreserved symbol.
e. Any Exchange with less than 1,000 symbols on reserve will NOT be required to give a symbol in
exchange when requesting a new symbol from the “Open List”.
f. Any Exchange with less than 1,000 symbols on reserve will be limited to 10 new symbol
assignments per month from the unreserved symbol repository.
g. Any symbol currently being contested will NOT be available for transfer. All disputes must be
resolved prior to transfer.
C2. Symbols Being Retired to the “Unreserved Symbol Repository”
a. If a symbol is delisted, moves to the NASDQ or becomes inactive for any reason, the symbol will
move into a hold status for 6 months. If after 6 months the symbol is not activated the symbol
will expire into the “Open List” upon reaching its 6‐month inactive anniversary date. (Excluding
symbols marked as “Exempt” – See “Exempt Symbols”).
b. Retired Leap Symbols in a hold status as of 02/06/2005 will expire into the “Unreserved Symbol
Repository” after 30 months (2.5 years) of inactivity.
c. All exchanges are urged to release unused symbols to the “Open List” to build up the number of
symbols available.
D. Reserved Symbol Repository:
Definition: “Reserved Symbol Repository” – Any symbol that is currently on reserve by any exchange. Symbols on
reserve include symbols in the “Active”, “Inactive” or “Exempt” status. Note: Symbols assigned to your exchange
and symbols available for transfer within the “Open” list are the only symbols that will be visible to your exchange.
D1. Requesting a symbol from the “Reserved Symbol Repository”
a. User may request any symbol from the “Open List”. If a symbol is on
reserve by another exchange you will receive the “Symbol is not available” message when
searching for the symbol you are requesting.
b. Symbol swaps are optional when requesting a symbol from another exchange.
c. Exchanges have the right to refuse to swap with a requesting exchange.
d. Any symbol in a Contested status will NOT be permitted as a symbol available for transfer or
exchange for another symbol.
Original 2004 Document: by SFB Market Systems Inc.
E. Exempt Symbols
a. These are symbols that exchanges choose to place on “Exempt” status to keep an inactive symbol
from expiring. The number of “Exempt” symbols per exchange may vary and are based on the service
plan your exchange is signed up for.
b. Maximum allowable “Exempt” symbols for any exchange will be 100.
G. Symbol Status Definitions:
a. Open – Symbol is available to be reserved
b. Reserved – Symbol is inactive but still reserved and will be held on
reserve for 6 months of inactivity after which it will be returned to the (O)pen status
c. Exempt – Symbols exempt from 6-month expiration / retirement rules
d. Active – Symbol is actively trading and/or contains open positions
e. Inactive – Symbol is not actively trading
F. Non-Participating Exchanges:
a. Each non-participating exchange will be provided with a Userid and password to view their
own symbols following the initial load. There will be no access to Open and Available symbols.
b. Each non-participating exchange will provide a correction list of symbols to be applied to the
Symbol Master Repository as a starting point for symbols on reserve by their exchange.
c. If a non-participating exchange does not provide SMCC with their own list of reserved symbols,
symbols will be assigned to the non-participating exchange from what the participating exchanges
have on file for the non-participating exchange.
d. If a symbol does not appear on any of the participating exchange lists (files) on behalf of the
non-participating exchange and the symbol is inactive (not currently trading), that symbol will be
assumed as open and available and will appear in the open and available list.
e. If a symbol is de-listed or becomes inactive by moving to the NASDQ, that symbol will be
date time-stamped on the date it stops trading. If that symbol is not reactivated within 6
months from the inactive date time-stamp the symbol will be released to the open and
available list upon its 6th month inactive anniversary date.
Original 2004 Document: by SFB Market Systems Inc.
Rock are you going to attend the SPZI Shareholder meeting ?
Second The TAX credit for the solar CO still in place
Endub one of them..
Small alternative energy names draw spotlight article
http://www.marketwatch.com/news/story/jesup-analyst-eyes-small-cap/story.aspx?guid=%7BDBCCFDF1%2D5148%2D484F%2DACB6%2DF0ABEE6B1E78%7D&siteid=yhoof
AKNS Solar demand is growing rapidly
Lol ) this message will stand !! Spzi need some reverse psychology..
Rock you are a star I'm impressed by your knowledge , any tips how you see Spooz share price in a few weeks ?
I feel a lot of disappointment in the air, and a PR from the company is extremely needed at this time to restore guidance . let the loyal shareholders share the buzz of the Chicago office ... Lack of information is not the way to go here ...
MC any idea why the OS increased ?
End Nice to see you here ,
I live in Ca and saw their products installed , They have a great strategy and IMo they will do well . However the CEo just sold a bunch of Shares due to a divorce procedure .. the stock fluctuate IMO it's undervalued right now ,We just have retrace of 50% . However I think the earnings in May 8th will surpass the projections and I do expect a valuation of 20% here ..
I think this post is worth to be seen again :
Speciailly with the obvious interactive Brokers link now official on Spooz's website ..
Posted by: alliecorp
In reply to: None
Date: 11/4/2007 9:20:33 PM
Post # of 402
Here are Paul's answers to investor questions. Thanks everyone for submitting your questions this week and last. And thanks Paul for taking the time to respond to them . allie
I apologize if I missed any questions. If so, please resend them for this week, thanks.
Allie,
My answers appear in red below.
Thanks again to our shareholders for asking the right questions and providing me with a venue to respond in an efficient manner.
All the Best,
Paul
----------------------------------------------------------------
1. Can you please comment on the relationship with Ameritrade and whether we still have a deal with them or WILL have a deal with them in the near future? Afterall this name was dropped a couple of months ago already.
We do have a marketing agreement in place with TDAmeritrade.
2. The same question about Interactive Brokers. A couple of weeks ago we learned that Interactive Brokers would be (is) very interested in ST2 because they have a lot of Professionals trading there.
We do have an affiliate agreement in place with IB and are in the process of negotiating a marketing agreement with them, together with several other large electronic execution providers. There are seven large targeted brokers for us that represent, what we project, represents 80% of our domestic market.
3. Is the issue "Fractalz" now obsolete because Dr.Peng He left the company?
Dr. Peng has absolutely nothing to do with Fractalz3.
4. Can you please tell us whether it's correct that SPZI forecasts a 50% net income margin on ST2 as you pointed out in one of the slides at the EXPO? If not how big will it be?
The projected gross margin for SpoozToolz is in excess of 80%.
5. Will SPZI ever do something against the huge number of outstanding shares once it makes money from operations? I mean clearly no company with o/s at 1.5 billion and trading under a penny a share will get taken seriously in the international market place. I guess if you really want to make "waves" in the "trading systems business world" out there I guess listing on the pink sheets is not looking very serious to others.
I can not comment on this at this time. We are concentrating on products and profitability at this time. After profitability is achieved, the solution to this problem will become much more clear.
6. Can you give us a rough estimate on how much the burn rate is for the company right now per quarter?
Less than $500,000. The successful sale of the SWARM license to 141 Capital could mean that Spooz will achieve a profitable Q4 2007.
7. Are you in any way concerned about possible competitors who might want to follow up with a similar product than ST2 is, especially given your recent delays of the launch? What I mean is shouldn't have Spooz launched the software as early as possible to have a "time advantage" against other companies maybe trying to come up with something similar or is everything totally secured because of the patents?
We are always concerned about competition. The level of competition will be commensurate with our financial success. This is the reason we are so focused upon rapid market penetration as opposed to time to market.
8. Did any serious interest come up from the EXPO?
We have seen considerable interest at an international level.
9. What advantage does it have to launch the 141 stock also in germany?
Access to additional working and trading capital together with marketing and distribution.
10. Is there any serious money lined up to invest into SWARM once this trading model generates a decent official track record? I guess it will not run with only 3 million very long in case it is successful, will it?
Trading capital for 141 will be subject to reportable trading track records. These questions should be submitted to Errol Stone.
11. I have always asked myself why Spooz is only going to get 7% of the net income numbers from 141/SWARM when in fact SWARM is owned 100% by Spooz. I mean I understand that the guys who arrange and provide the money get a decent piece of the pie but could you help us understand why that is 93% of the net income? I realize that many investors didn't understand this in the first place and were disappointed by it.
I believe I have answered this question many time before. We believe that, overall, the Spooz/141 deal is very generous to Spooz shareholders especially since SWARM is one of many potential proprietary trading systems that will be employed by 141 Capital.
12. Is there anything still to become official out of the "quiet period" or was the 141 license deal in regards to futures for SWARM the only thing that got developed during the quiet period? I guess I'm asking because a couple of weeks ago you said that this is just "the tip of the iceberg" and so we hoped that somethin else is coming out of this quiet period soon....
More of the “iceberg” will become visible in the next few weeks. There are a great many things to be revealed to our shareholders, but timing is everything.
News is coming /E
Biganc Lol you're right: It feels like I walked in somebody else House here ..
great energy ahead , young wolves )
I want to congratulate MC , Allie and Wing on the other Boar for their dedication and inspiration here when dealing with rough time !
Good for you Bocca This is going to $
Bocca I have 15 mil here locked for 3 years !No Selling whatsoever
Nice to see a lot of new faces here )
xxis up 275% low float 100 million 10 bagger potential 0.0015
uranium you have no idea cent and other have been around over 2 years now and the shares are locked , on my side they are ,,)
nite 0.001 then HDsn*2 0.0018 and then Etrd*2 0.003
bid 0.0008 ask 0.0009
XXIS up 125 % 100 million float ! 0.0009
as of today the OS is still the same :
1.857,696.424 ...
Fire here we go
http://www.spooz.com/investors.aspx and download the pdf file
Same here Mc . if they diluted to the max and let's assume that the shares won't be restricted . then we are talking another 150 million still to go . I will try my best to buy them all ,I have time and I do know where I'm going ...
Actually this is turning to be as a monumental opportunity ... Thank you Pink Thank you for people selling in fear , thank you very much
165 millions to go to max the OS .
Let's buy softly the balance and come back in 6 months !
As of of today the OS
is 1.857,696.424 ...
all my buys looks like sell !
Same than yesterday see post #47089 , so it's not the company selling ,
may be tax reason ?
Poc you have no idea what you are talking about , Investigation will start with you ...