Exhibit 99.1

            No Action Letter issued by Securities Exchange Commission
         dated January 6, 2003 to operate Track ECN through July 6, 2003


James C. Yong
Wildman, Harrrold, Allen & Dixon
225 West Wacker Drive
Chicago, IL  60606-1229

     Re:  Track System

Dear Mr. Yong:

     This letter extends the temporary no-action position originally taken by
the Division of Market Regulation ("Division") on January 7, 2002 until July 6,
2003.  The January 7th letter 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 (cumulatively, "Order Execution Rules") and
would be in compliance with the requirements applicable to the ECN Display
Alternative set forth in the ECN Amendment with respect to Nasdaq securities for
which a linkage between the System and the Nasdaq system is operational.  In the
January 7th letter, the Division took the position that it would not recommend
the Commission take enforcement action against Nasdaq market makers who are
participants in the System, if those Nasdaq market makers enter orders into the
System without modifying their public quotations in compliance with the ECN
Amendment.  That no-action position was temporarily extended most recently in a
letter dated March 29, 2002.

     The Division continues to condition its position on compliance with the
terms expressed in the January 7th letter.  These terms include compliance with
the non-discrimination provisions of the Addendum to the Nasdaq Workstation II
Subscriber Agreement.  Track ECN should respond to orders entered into Track ECN
through Nasdaq access no slower than Track ECN responds to orders entered
directly into the System, and in any event in no more than a few seconds.

     The Division further conditions its position upon your representation that
Track ECN has sufficient capacity to handle the volume of trading reasonably
anticipated in its System.  Such capacity should be ensured through periodic
review and testing to (1) ensure future capacity, (2) identify potential
weaknesses, and (3) reduce the risk of system failures and threats to system
integrity.  The Division may request records from Track regarding such reviews
and tests.

     The Division further conditions its position on Track providing brokers
access via either Nasdaq or the telephone for a charge of no more than the fee
Track charges a substantial proportion of its active broker-dealer subscribers,
and in any event, no more that $.009 per share, plus any fee charged to the
System by Nasdaq and plus any application transaction fee payable pursuant to
Section 31 of the Securities Exchange Act of 1934 ("Exchange Act").  In
addition, the Division may request additional representations from you regarding
the operation of the System.

     The Division further conditions its position upon your representation that
the trading information entered into the System will be kept confidential by
those employees of Track having access to it, and that the operation of the
System will be kept separate from the other business of Track.  The Division, in
the process of its continuing review of ECNs, may request records concerning
procedures addressing these issues.  Further, the Division will consider
extending or modifying its temporary no-action position prior to July 6, 2003,
based on its continuing experience with the operation of the ECN Display
Alternative.

     This no-action position regards enforcement action under Section 11A of the
Exchange Act only, and does not express any legal conclusions regarding the
applicability of Section 11A of the Exchange Act or other statutory or
regulatory provisions of the federal securities laws.  This no-action position
is based solely on the representations you have made.  Any different facts or
conditions might require a different response.  This no-action position is
subject to changes in current law, regulation, and interpretations; any such
change may require the Division to reevaluate and withdraw or modify this
position.

          Sincerely,



/s/
-----------------------------------
     Robert L.D. Colby
     Deputy Director