Notice2025-18939

Self-Regulatory Organizations; Nasdaq PHLX LLC; Notice of Filing and Immediate Effectiveness of Proposed Rule Change To Amend Market Data Feed Descriptions and Fees

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Published
September 30, 2025

Issuing agencies

Securities and Exchange Commission

Full Text

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<title>Federal Register, Volume 90 Issue 187 (Tuesday, September 30, 2025)</title>
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[Federal Register Volume 90, Number 187 (Tuesday, September 30, 2025)]
[Notices]
[Pages 47096-47105]
From the Federal Register Online via the Government Publishing Office [<a href="http://www.gpo.gov">www.gpo.gov</a>]
[FR Doc No: 2025-18939]


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SECURITIES AND EXCHANGE COMMISSION

[Release No. 34-104049; File No. SR-Phlx-2025-53]


Self-Regulatory Organizations; Nasdaq PHLX LLC; Notice of Filing 
and Immediate Effectiveness of Proposed Rule Change To Amend Market 
Data Feed Descriptions and Fees

September 25, 2025.
    Pursuant to Section 19(b)(1) of the Securities Exchange Act of 1934 
(``Act''),\1\ and Rule 19b-4 thereunder,\2\ notice is hereby given that 
on September 24, 2025, Nasdaq PHLX LLC (``Phlx'' or ``Exchange'') filed 
with the Securities and Exchange Commission (``Commission'') the 
proposed rule change as described in Items I, II, and III, below, which 
Items have been prepared by the Exchange. The Commission is publishing 
this notice to solicit comments on the proposed rule change from 
interested persons.
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    \1\ 15 U.S.C. 78s(b)(1).
    \2\ 17 CFR 240.19b-4.
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I. Self-Regulatory Organization's Statement of the Terms of Substance 
of the Proposed Rule Change

    The Exchange proposes to amend (1) Phlx's market data feed 
descriptions at Options 3, Section 23, Data Feeds and Trade 
Information; and (2) Phlx's market data pricing at Options 7, Section 
9, B, Port Fees, and Section 10, Proprietary Data Feeds Fees, to set 
fees for two new feeds, the Trades Feed and the Spread Feed.
    While these amendments are effective upon filing, the Exchange will 
implement this rule change on or before December 20, 2025. The Exchange 
will announce the operative date to members and member organizations in 
an Options Trader Alert.
    The text of the proposed rule change is available on the Exchange's 
website at <a href="https://listingcenter.nasdaq.com/rulebook/phlx/rulefilings">https://listingcenter.nasdaq.com/rulebook/phlx/rulefilings</a>, 
and at the principal office of the Exchange.

II. Self-Regulatory Organization's Statement of the Purpose of, and 
Statutory Basis for, the Proposed Rule Change

    In its filing with the Commission, the Exchange included statements 
concerning the purpose of and basis for the proposed rule change and 
discussed any comments it received on the proposed rule change. The 
text of these statements may be examined at the places specified in 
Item IV below. The Exchange has prepared summaries, set forth in 
sections A, B, and C below, of the most significant aspects of such 
statements.

A. Self-Regulatory Organization's Statement of the Purpose of, and 
Statutory Basis for, the Proposed Rule Change

1. Purpose
    This proposal amends (1) Phlx's market data feed descriptions at 
Options 3, Section 23, Data Feeds and Trade Information; and (2) Phlx's 
market data pricing at Options 7, Section 9, B, Port Fees, and Section 
10, Proprietary Data Feed Fees. Each change is described below.
Market Data Feed Descriptions
    The Exchange proposes to amend its market data feed descriptions in 
Options 3, Section 23, Data Feeds and Trade Information. Today, the 
Exchange offers 3 market data feeds: (1) Nasdaq Phlx Top of Market, (2) 
Nasdaq Phlx Order Feed, and (3) Nasdaq Phlx Depth of Market.\3\ These 
data feeds provide information on both single-leg orders and complex 
orders.
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    \3\ The Exchange made minor amendments to Options 3, Section 
23(a) in SR-Phlx-2024-71. See Securities Exchange Act Release No. 
101989 (December 30, 2024), 89 FR 106888 (December 30, 2024) (SR-
Phlx-2024-71). SR-Phlx-2024-71 is effective but not yet operative. 
The amendments to SR-Phlx-2024-71 will be implemented at the same 
time as this proposal.
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    At this time, the Exchange proposes to harmonize its market data 
feeds at Options 3, Section 23(a) to Nasdaq ISE, LLC's (``ISE'') market 
data feeds at Options 3, Section 23(a) in connection with the 
technology migration. This harmonization will result in some 
enhancements to its current data feed offerings. Today, ISE offers the 
following market data feeds: (1) Nasdaq ISE Depth of Market Data Feed, 
(2) Nasdaq ISE Order Feed, (3) Nasdaq ISE Top of Market Feed, (4) 
Nasdaq ISE Trades Feed, and (5) Nasdaq ISE Spread Feed.
Nasdaq Phlx Top of Market
    Currently, the Nasdaq Phlx Top of Market data feed at Options 3, 
Section 23(a)(1) provides,

    Nasdaq Phlx Top of Market (``TOPO'') is a direct data feed 
product that includes the Exchange's best bid and offer price, with 
aggregate size, based on displayable order and quoting interest on 
Phlx and last sale information for trades executed on Phlx. The data 
contained in the TOPO data feed is identical to the data 
simultaneously sent to the processor for the OPRA and subscribers of 
the data feed. The data provided for each options series includes 
the symbols (series and underlying security), put or call indicator, 
expiration date, the strike price of the series, and whether the 
option series is available for trading on Phlx and identifies if the 
series is available for closing transactions only.

    The Exchange proposes to amend the description of the TOPO data 
feed to align the content of the feed to the Nasdaq ISE Top of Market 
Feed at Options 3, Section 23(a)(3). The Exchange proposes to provide 
in the first sentence, ``. . . calculates and disseminates the 
Exchange's best bid and offer position, with aggregate size (including 
total size in aggregate, for Professional Order size in the aggregate 
and Public Customer Order size in the aggregate), based on displayable 
order and quote interest in the System.'' This proposed rule text adds 
more specificity around aggregate size by noting that it includes total 
size in aggregate, for Professional Order size in the aggregate

[[Page 47097]]

and Public Customer Order size in the aggregate. Today, aggregate size 
on Phlx is as described in the proposed rule text. The proposed 
language clarifies the current rule but does not substantively amend 
the rule.
    The Exchange further proposes to modify the reference to last sale 
information in the definition of TOPO to align it with the content of 
the comparable top of book feeds contained in the ISE, MRX and GEMX 
rulebooks. This is part of the overall harmonization of the Phlx 
platform with those of other Nasdaq affiliated markets in Phlx's 
upcoming technology migration.\4\ Once the migration is completed, Phlx 
will have five market data feeds: (i) a depth of market feed, (ii) an 
order feed; (iii) a top of market feed; (iv) a trades feed; and (v) a 
spreads feed that are comparable to those on ISE, MRX and GEMX.\5\
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    \4\ As noted below, the proposed rule change will be implemented 
on or before December 20, 2025. See <a href="https://www.nasdaqtrader.com/MicroNews.aspx?id=OTA2024-17">https://www.nasdaqtrader.com/MicroNews.aspx?id=OTA2024-17</a>.
    \5\ As noted above, this filing is modeled after the ISE 
exchange, which today offers the following market data feeds: (1) 
Nasdaq ISE Depth of Market Data Feed, (2) Nasdaq ISE Order Feed, (3) 
Nasdaq ISE Top of Market Feed, (4) Nasdaq ISE Trades Feed, and (5) 
Nasdaq ISE Spread Feed. MRX has the same five data feed categories: 
depth of book, an order feed, a top of market feed, a trades feed, 
and a spread feed. GEMX offers depth of book, an order feed, a top 
of market feed, and a trades feed, but does not offer a spread feed 
because it does not process complex orders.
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    Conforming Phlx's data feeds to those of other Nasdaq affiliated 
markets will allow subscribers to reduce information processing costs 
by formatting their data processing systems on a common platform for 
Nasdaq markets. It will enable customers to ingest information from all 
Nasdaq exchanges without modifying their intake systems to ingest 
information using different exchange formats. This is a change from 
current practice, in which each exchange offers its own unique set of 
market data feeds, requiring subscribers to separately program their 
systems to ingest information from each distinct market. As such, the 
reference to last sale information \6\ in the definition of Phlx TOPO 
will be removed to conform it to the content of the top of book feeds 
of ISE, MRX and GEMX.\7\
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    \6\ This last sale information includes the ticker, time, option 
ID, last price, last traded quantity, total traded quantity, high/
low for day, opening price and trade condition for each option 
traded on Phlx.
    \7\ See Supra note 4.
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    ISE, MRX and GEMX offer last sale information in a separate, 
standalone data feed, the Trades Feed.\8\ As discussed in further 
detail below, Phlx proposes to create a Trades Feed on the model of 
ISE, MRX and GEMX. Nasdaq proposes to offer the Trades Feed at no 
additional cost with the purchase of TOPO. A separate fee for the 
Trades Feed will be proposed at a later date.
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    \8\ As explained below, the proposed Trades Feed for Phlx will 
display last trade information, including the symbols (series and 
underlying security), put or call indicator, expiration date, the 
strike price of the series, and whether the option series is 
available for trading on Phlx and identifies if the series is 
available for closing transactions only. Last sale information will 
also be included on the proposed Spread Feed, replicating the feed 
available on ISE today.
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    With the proposed amendments, the description of the TOPO data feed 
at Options 3, Section 23(a)(1) would provide,\9\
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    \9\ The Nasdaq ISE Top of Market Feed at Options 3, Section 
23(a)(3) has a sentence that provides, ``The feed also provides 
order imbalances on opening/reopening.'' ISE is separately filing to 
remove that sentence from its Top Feed.

    Nasdaq Phlx Top of Market (``TOPO'') calculates and disseminates 
the Exchange's best bid and offer position, with aggregate size 
(including total size in aggregate, for Professional Order size in 
the aggregate and Public Customer Order size in the aggregate), 
based on displayable order and quote interest in the System. The 
data contained in the TOPO data feed is identical to the data 
simultaneously sent to the processor for the OPRA and subscribers of 
the data feed. The data provided for each options series includes 
the symbols (series and underlying security), put or call indicator, 
expiration date, the strike price of the series, and whether the 
option series is available for trading on Phlx and identifies if the 
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series is available for closing transactions only.

    Currently, the Nasdaq Phlx Order Feed at Options 3, Section 
23(a)(2) provides,

    Nasdaq Phlx Order Feed is a real-time full Limit Order book data 
feed that provides pricing information for orders on the Phlx Order 
book for displayed order types as well as market participant 
capacity. Nasdaq Phlx Order Feed is currently provided as part of 
the TOPO Plus Orders data product. The Nasdaq Phlx Order Feed 
provides real-time information to enable users to keep track of the 
single and complex order book(s). The data provided for each options 
series includes the symbols (series and underlying security), put or 
call indicator, expiration date, the strike price of the series, leg 
information on complex strategies and whether the option series is 
available for trading on Phlx and identifies if the series is 
available for closing transactions only. The feed also provides 
auction and exposure notifications and order imbalances on opening/
reopening (size of matched contracts and size of the imbalance).

    The Exchange proposes to amend the description of the Nasdaq Phlx 
Order Feed or ``Order Feed,'' as proposed, to align the content of the 
feed to the Nasdaq ISE Top of Market Feed at ISE Options 3, Section 
23(a)(2). The Exchange proposes to add in the first sentence, ``. . . 
provides pricing information on new orders resting on the Phlx Order 
Book (e.g. price, quantity, market participant capacity and 
Attributable Order tags when provided by a Member).'' The Exchange 
proposes to add examples to provide more context to the Order Feed and 
to introduce Attributable Order tags. The Exchange recently adopted 
Attributable Orders at Options 3, Section 7(h) \10\ that are identical 
to ISE Attributable Orders Options 3, Section 7(h). The Exchange 
proposes to relocate the wording regarding displayed order types to the 
fourth sentence and state, ``The data provided for each options series 
includes the symbols (series and underlying security), displayed order 
types, order attributes (e.g., OCC account number, give-up information, 
CMTA information) . . .''. The Exchange recently adopted a Reserve 
Order at Options 3, Section 7(g) \11\ that is identical to ISE Reserve 
Orders at Options 3, Section 7(g). The Exchange will continue to 
provide auction and exposure notifications and order imbalances on 
opening/reopening (size of matched contracts and size of imbalance) on 
the Order Feed as it does now.
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    \10\ See Securities Exchange Act Release No. 101989 (December 
30, 2024), 89 FR 106888 (December 30, 2024) (SR-Phlx-2024-71). SR-
Phlx-2024-71 is effective but not yet operative. The amendments to 
SR-Phlx-2024-71 will be implemented at the same time as this 
proposal.
    \11\ Id.
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    The Exchange proposes to remove complex order details from the 
Order Feed. Complex order data will be included in a new Nasdaq Phlx 
Spread Feed as discussed below.\12\ Nasdaq proposes to offer the Spread 
Feed at no additional cost with the purchase of the Order Feed. A 
separate fee for the Spread Feed will be proposed at a later date.
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    \12\ The proposed Spread Feed will provide complex order 
information, including top of market, order and trade message 
components. The current top of market, orders and depth of market 
feeds will continue to provide information for single leg orders. 
Consolidating complex order information on the new Spread Feed will 
allow customers to access all complex order information in a single, 
consolidated location, as is currently available on ISE and MRX.
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    The Exchange also proposes to remove the sentence that provides, 
``The Nasdaq Phlx Order Feed provides real-time information to enable 
users to keep track of the single and complex order book(s)'' because 
the Order Feed is for single-leg data only. With the proposed 
amendments, the description of the TOPO data feed at Options 3, Section 
23(a)(2) would provide,

    Nasdaq Phlx Order Feed (``Order Feed'') provides pricing 
information on new orders

[[Page 47098]]

resting on the Phlx Order book (e.g., price, quantity, market 
participant capacity and Attributable Order tags when provided by a 
Member). Nasdaq Phlx Order Feed is currently provided as part of the 
TOPO Plus Orders data product. The data provided for each options 
series includes the symbols (series and underlying security), 
displayed order types, order attributes (e.g., OCC account number, 
give-up information, CMTA information), put or call indicator, 
expiration date, the strike price of the series, and whether the 
option series is available for trading on Phlx and identifies if the 
series is available for closing transactions only. The feed also 
provides auction and exposure notifications and order imbalances on 
opening/reopening (size of matched contracts and size of the 
imbalance).

    Currently, the Nasdaq Phlx Depth of Market data feed at Options 3, 
Section 23(a)(3) provides,

    Nasdaq Phlx Depth of Market is a data product that provides: (i) 
order and quotation information for individual quotes and orders on 
the order book; (ii) last sale information for trades executed on 
Phlx; (iii) auction; and (iv) an Imbalance Message which includes 
the symbol, side of the market, size of matched contracts, size of 
the imbalance, and price of the affected series. The data provided 
for each options series includes the symbols (series and underlying 
security), put or call indicator, expiration date, the strike price 
of the series, and whether the option series is available for 
trading on Phlx and identifies if the series is available for 
closing transactions only. The feed also provides order imbalances 
on opening/reopening (size of matched contracts and size of the 
imbalance) and exposure notifications, with market participant 
capacity.

    The Exchange proposes to amend the description of the Nasdaq Phlx 
Depth of Market data feed or ``Depth of Market Feed,'' as proposed, to 
align the content of the feed to the Nasdaq ISE Depth of Market Data 
Feed at ISE Options 3, Section 23(a)(1). The Exchange proposes to amend 
the first sentence to state, ``. . . is a data feed that provides full 
order and quote depth information for individual quotes and orders on 
the order book and last sale information for trades executed on Phlx.'' 
This amendment is non-substantive as it merely rewords the current 
sentence to align it to the first sentence of ISE Options 3, Section 
23(a)(1). The Exchange proposes to remove the reference to auction 
information and the ``Imbalance Message which includes the symbol, side 
of the market, size of matched contracts, size of the imbalance, and 
price of the affected series.'' The Exchange would continue to offer 
``order imbalance information on opening/reopening (size of matched 
contracts and size of the imbalance),'' however, as indicated in the 
final sentence of the description. The only substantive difference 
between the old and the new feeds in this context is that the Exchange 
will not provide exposure notifications with market participant 
capacity information on the new Depth of Market Feed.\13\ Specifically, 
the current feed identifies order exposure by capacity, such as, for 
example, Customer or Firm. The new feed will no longer include that 
association. The Exchange regards this to be an immaterial 
modification. Both exposure notifications and market capacity 
information are currently offered, and will continue to be offered, on 
the Order Feed. With the proposed amendments, the description of the 
Depth of Market Feed at Options 3, Section 23(a)(2) would provide,
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    \13\ The new Depth of Market Feed will, however, include a 
tracking number not included in the old feed, which will also be 
provided on the Exchange's other market data feeds, allowing 
participants to keep track of orders across data feeds, as discussed 
further below.

    Nasdaq Phlx Depth of Market (``Depth of Market Feed'') is a data 
feed that provides full order and quote depth information for 
individual quotes and orders on the order book and last sale 
information for trades executed on Phlx. The data provided for each 
options series includes the symbols (series and underlying 
security), put or call indicator, expiration date, the strike price 
of the series, and whether the option series is available for 
trading on Phlx and identifies if the series is available for 
closing transactions only. The feed also provides order imbalances 
on opening/reopening (size of matched contracts and size of the 
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imbalance).

    Today, ISE offers the Nasdaq ISE Trades Feed (``Trades Feed'') at 
Options 3, Section 23(a)(4). This feed displays last trade 
information.\14\ The data provided for each option series includes the 
symbols (series and underlying security), put or call indicator, 
expiration date, the strike price of the series, and whether the option 
series is available for trading on ISE and identifies if the series is 
available for closing transactions only. The Exchange proposes to adopt 
a market data feed identical to the Trades Feed at proposed Phlx 
Options 3, Section 23(a)(4) and title the feed the ``Nasdaq Phlx Trades 
Feed'' or ``Trades Feed.'' As adopted, Phlx Options 3, Section 23(a)(4) 
will provide:
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    \14\ The last sale information includes the time of the trade, 
instrument ID, cross ID, transaction price and current number of 
contracts traded for each option traded on Phlx.

    Nasdaq Phlx Trades Feed (``Trades Feed'') displays last trade 
information. The data provided for each option series includes the 
symbols (series and underlying security), put or call indicator, 
expiration date, the strike price of the series, and whether the 
option series is available for trading on Phlx and identifies if the 
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series is available for closing transactions only.

    Today, ISE offers a Nasdaq ISE Spread Feed (``Spread Feed'') at 
Options 3, Section 23(a)(5). The ISE Spread Feed consists of: (1) 
options orders for all Complex Orders (i.e., spreads, buy-writes, delta 
neutral strategies, etc.); (2) full Complex Order depth information, 
including prices, side, size, capacity, Attributable Complex Order tags 
when provided by a Member, and order attributes (e.g., OCC account 
number, give-up information, CMTA information), for individual Complex 
Orders on the Exchange book; (3) last trades information; and (4) 
calculating and disseminating ISE's complex best bid and offer 
position, with aggregated size (including total size in aggregate, for 
Professional Order size in the aggregate and Priority Customer Order 
size in the aggregate), based on displayable Complex Order interest in 
the System. The feed also provides Complex Order auction notifications. 
The Exchange proposes to adopt a market data feed identical to the 
Spread Feed at proposed Phlx Options 3, Section 23(a)(5) and title the 
feed the ``Nasdaq Phlx Spread Feed'' or ``Spread Feed.'' As adopted, 
Options 3, Section 23(a)(5) will provide:

    Nasdaq Phlx Spread Feed (``Spread Feed'') is a feed that 
consists of: (1) options orders for all Complex Orders (i.e., 
spreads, buy-writes, delta neutral strategies, etc.); (2) full 
Complex Order depth information, including prices, side, size, 
capacity, Attributable Complex Order tags when provided by a member 
or member organization, and order attributes (e.g., OCC account 
number, give-up information, CMTA information), for individual 
Complex Orders on the Exchange book; (3) last trades information; 
and (4) calculating and disseminating Phlx's complex best bid and 
offer position, with aggregated size (including total size in 
aggregate, for Professional Order size in the aggregate and Public 
Customer Order size in the aggregate), based on displayable Complex 
Order interest in the System. The feed also provides Complex Order 
auction notifications.

    Similar to ISE, Phlx complex order data would be separately 
disseminated through the proposed Spread Feed.\15\
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    \15\ With this proposed change, a spread feed will be offered by 
ISE, MRX and Phlx. GEMX does not offer a spread feed because it does 
not process complex orders.
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Fees
    Phlx proposes to amend its Pricing Schedule at Options 7, Section 
10, Proprietary Data Fees, to adopt fees for the newly proposed Nasdaq 
Phlx Trades Feed and the Nasdaq Phlx Spread Feed.
    The Exchange also proposes to amend its pricing schedule at Options 
7,

[[Page 47099]]

Section 9(B) to change the name of the ``PHLX Orders Port Fee'' to 
``Nasdaq Phlx Order Feed Port Fee'' and the name of the PHLX Depth of 
Market Port Fee'' to the ``Nasdaq Phlx Depth of Market Port Fee.'' It 
also proposes adding ``Nasdaq Phlx Trades Feed'' and ``Nasdaq Phlx 
Spread Feed'' to the list of port fees. The proposed fees for all five 
of these port is $0 per port, per month.
Nasdaq Phlx Trades Feed
    Nasdaq proposes to offer the Trades Feed at no additional cost with 
the purchase of TOPO.\16\
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    \16\ A fee for the Trades Feed will be proposed at a later date.
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Nasdaq Phlx Spread Feed
    Nasdaq proposes to offer the Spread Feed at no additional cost with 
the purchase of the Order Feed.\17\
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    \17\ A fee for the Spread Feed will be proposed at a later date.
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Implementation
    The Exchange will implement this rule change on or before December 
20, 2025.\18\ The Exchange will announce the operative date to members 
and member organizations in an Options Trader Alert.
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    \18\ See <a href="https://www.nasdaqtrader.com/MicroNews.aspx?id=OTA2024-17">https://www.nasdaqtrader.com/MicroNews.aspx?id=OTA2024-17</a>. PHLX will migrate to the new platform on a symbol-by-symbol 
basis over a 5 week period. The Exchange notes that the amendments 
to the Phlx rules noted in SR-Phlx-2024-71 and this proposal will be 
implemented as part of this same technology migration. See 
Securities Exchange Act Release No. 101989 (December 30, 2024), 89 
FR 106888 (December 30, 2024) (SR-Phlx-2024-71). SR-Phlx-2024-71 is 
effective but not yet operative.
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2. Statutory Basis
    The Exchange believes that its proposal is consistent with Section 
6(b) of the Act,\19\ in general, and furthers the objectives of Section 
6(b)(5) of the Act,\20\ in particular, in that it is designed to 
promote just and equitable principles of trade, to remove impediments 
to and perfect the mechanism of a free and open market and a national 
market system, and, in general to protect investors and the public 
interest. Additionally, the Exchange believes that its proposal 
furthers the objectives of Sections 6(b)(4) and 6(b)(5) of the Act,\21\ 
in particular, in that it provides for the equitable allocation of 
reasonable dues, fees, and other charges among members and issuers and 
other persons using any facility, and is not designed to permit unfair 
discrimination between customers, issuers, brokers, or dealers.
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    \19\ 15 U.S.C. 78f(b).
    \20\ 15 U.S.C. 78f(b)(5).
    \21\ See 15 U.S.C. 78f(b)(4) and (5).
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    The Proposal is an equitable allocation of fees because the 
proposed fees would apply to all market participants in a uniform 
manner.
    The Proposal is not unfairly discriminatory. The proposed feeds are 
optional data fees available to all market participants on a non-
discriminatory basis.
Market Data Feed Definitions
    The Exchange believes that the proposed changes to the current data 
feed offerings in Phlx Options 3, Section 23(a) are consistent with the 
Act. Specifically, the Exchange believes that the proposed changes to 
TOPO, the Order Feed and the Depth of Market Feed will serve to align 
the information provided on Phlx to that provided in identical feeds at 
ISE (namely, Nasdaq ISE Depth of Market Data Feed, Nasdaq ISE Order 
Feed, and Nasdaq ISE Top of Market Feed at Options 3, Section 23(a)(1)-
(3)), thereby ensuring a more consistent technology offering across the 
Nasdaq affiliated options exchanges.\22\
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    \22\ The Exchange also notes that Nasdaq MRX, LLC (``MRX'') has 
identical market data feed to ISE at Options 3, Section 23(a)(1)-
(3). With this proposed change all Nasdaq options markets that offer 
complex order functionality would offer identical data feeds.
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    The Exchange also believes that the modified TOPO feed will help to 
protect a free and open market by providing additional specificity 
concerning aggregate size. While the Exchange is removing the last sale 
information from the TOPO feed, the Exchange notes that it proposes to 
align it with the definitions of the comparable top of book feeds 
contained in the ISE, MRX and GEMX rulebooks.
    Phlx proposes to harmonize its data feeds to those of other Nasdaq 
affiliated markets. Once the migration is completed, Phlx will have 
five market data feeds: (i) a depth of market feed, (ii) an order feed; 
(iii) a top of market feed; (iv) a trades feed; and (v) a spreads feed 
\23\ that are comparable to those on ISE and MRX. Further, the proposed 
Order Feed will offer information regarding additional displayed order 
types and commence offering order attribute data (e.g., OCC account 
number, give-up information, CMTA information). The proposed changes 
will also add more specificity around aggregate size thereby promoting 
transparency and clarity in the Exchange's rules.
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    \23\ As noted above, this filing is modeled after the ISE 
exchange, which today offers the following market data feeds: (1) 
Nasdaq ISE Depth of Market Data Feed, (2) Nasdaq ISE Order Feed, (3) 
Nasdaq ISE Top of Market Feed, (4) Nasdaq ISE Trades Feed, and (5) 
Nasdaq ISE Spread Feed.
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    The Exchange believes that the proposed changes to the Nasdaq Phlx 
Depth of Market data feed to no longer provide exposure notifications 
with market participant capacity information is consistent with the 
Act, as order imbalance information would continue to be offered in the 
Phlx Order Feed, and the information removed is immaterial to the Depth 
Feed. The proposal will serve to further align similar data feeds at 
ISE Options 3, Section 23(a)(1) and (2), thereby ensuring a more 
consistent technology offering across the Nasdaq affiliated options 
exchanges.
    The Exchange's proposal to adopt a Phlx Trades Feed at Options 3, 
Section 23(a)(4) that is identical to the ISE Trades Feed at Options 3, 
Section 23(a)(4) is consistent with the Act because Phlx members and 
member organizations will have the opportunity to elect to subscribe to 
the same feed offered today on ISE.\24\ Similarly, the Exchange's 
proposal to adopt a Phlx Spread Feed at Options 3, Section 23(a)(5) 
that is identical to the ISE Spread Feed at Options 3, Section 23(a)(5) 
is consistent with the Act because Phlx members and member 
organizations will have the opportunity to elect to subscribe to the 
same feed offered today on ISE.\25\ These offerings will ensure a more 
consistent technology offering across the Nasdaq affiliated options 
exchanges.
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    \24\ MRX and Nasdaq GEMX, LLC (``GEMX'') offer an identical 
Trades Feed at Options 3, Section 23(a)(1)(4) to the ISE Trades Feed 
and the proposed Phlx Trades Feed.
    \25\ MRX offer an identical Spread Feed at Options 3, Section 
23(a)(1)(5) to the ISE Spread Feed and the proposed Phlx Spread 
Feed.
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Proprietary Data Fees
The Proposed Proprietary Data Fees Are Reasonable, Equitable and Not 
Unfairly Discriminatory
    The Exchange believes that its proposal furthers the objectives of 
Sections 6(b)(4) and 6(b)(5) of the Act,\26\ in particular, in that it 
provides for the equitable allocation of reasonable dues, fees, and 
other charges among members and issuers and other persons using any 
facility, and is not designed to permit unfair discrimination between 
customers, issuers, brokers, or dealers. This belief is based on the 
fact that the proposal will enhance our market data products while at 
the same time maintaining fees that are comparable to those charged by 
similarly situated options exchanges.
---------------------------------------------------------------------------

    \26\ See 15 U.S.C. 78f(b)(4) and (5).

---------------------------------------------------------------------------

[[Page 47100]]

Product Enhancements
    The proposal offers three significant product enhancements. First, 
it will offer customers additional information on complex orders. 
Second, it is an essential element of Nasdaq's overall plan to 
standardize market data feeds across Nasdaq options exchanges, which 
will allow customers to ingest data more efficiently, and may result in 
customer cost saving. Third, the apportionment of market data across 
five feeds will allow customers to tailor their acquisition to only the 
data they need.
    Additional information: The Phlx Order Feed currently provides 
information on complex orders (option order comprising of one or more 
legs), such as order messages, updates on resting orders, and auction 
notification messages. The proposed modifications will significantly 
enhance customer insight into complex orders by associating top of 
market, order, depth of market and trade information with a unique 
strategy identification number that will allow customers to identify 
different stages of a trade as elements of a single complex order, 
providing market participants with much greater transparency into 
complex order activity. Such information is already an integral part of 
the feeds available on the MRX, ISE and GEMX exchanges, and its 
inclusion on the Phlx exchange will expand the availability of this 
invaluable information.
    Data Feed Optimization: Offering the same set of data feeds on all 
Nasdaq options markets will enable subscribers to ingest data more 
efficiently by using the same set of specifications to ingest market 
data from multiple markets. This will allow subscribers to onboard and 
maintain access to market data more efficiently, which may result in 
cost savings for the subscriber. The ISE, MRX and GEMX feeds already 
follow this standard format; this proposal will add a fourth exchange 
to that list, and Nasdaq is planning to submit future proposals to add 
the BX Exchange and the Nasdaq Options Market.
    Optionality: The proposed structure composed of five specialized 
feeds will allow subscribers to purchase only the data they need. This 
is more efficient and cost effective than requiring customers to 
distill information from a single large data feed, which can be quite 
large given the quantity of data generated by options trading. The 
five-feed structure also allows customers to configure their hardware 
to balance system loads more efficiently.
    We expect our customers to take advantage of these additional 
options. Our experience with the ISE Exchange--which already offers a 
trades feed that is distinct from its top of book feed--shows that 
nearly a third of customers take either take the top of market feed 
only (approximately 17%) or the trades feed only (about 14%), while the 
remaining customers take both. We expect the same pattern to hold true 
for Phlx--about a third of customers will take one feed or the other, 
ingesting less data than would be required for a combined feed, and the 
remaining customers to take both feeds.
    We expect that removing complex orders from the Order Feed and 
creating the new Spread Feed will enhance customer choice in a similar 
manner. The ISE Exchange offers an Order Feed that does not include 
complex orders, and a Spread Feed that does. Our experience with the 
ISE Exchange shows that approximately 45% of customers take either take 
the Spread Feed only (approximately 39%) or the Order Feed only (about 
7%), while the remaining customers take both. We expect the same 
pattern to hold true for Phlx--somewhat less than half the customers 
will take one feed or the other, while the remaining customers will 
take both.
Comparability Analysis
    As discussed in detail below, the proposed feeds are identical to 
those of ISE, GEMX and MRX. Also, the proposed fees remain essentially 
unchanged from the current fee schedule. Although the current TOPO feed 
is proposed to be split into a new TOPO feed and a new Trades Feed, the 
Trades Feed will be offered in conjunction with TOPO for no additional 
cost, so there will be no change in fees for the customer. Similarly, 
the current Order Feed is proposed to be split into an Order Feed and a 
Spread Feed, but the new Spread Feed will be offered with the Order 
Feed at no additional cost, so there will be no change in fees.
    Although there is an immaterial change to the Depth Feed regarding 
order exposure by capacity, the Exchange regards this to be an 
immaterial modification, and therefore fees for the Depth Feed remain 
essentially unchanged.
    Further, for the reasons set forth below, fees for the Phlx remain 
comparable to those of the ISE, GEMX, and MRX exchanges relative to 
market share, as set forth below.
Calculation of Market Share
    For the comparability analysis, the Exchange assessed market share 
\27\ for each of the eighteen options markets based on total options 
contracts traded in 2024 through October 28, 2024, as set forth in the 
graph below.
---------------------------------------------------------------------------

    \27\ Market share is the percentage of volume on a particular 
exchange relative to the total volume across all exchanges and 
indicates the amount of order flow directed to that exchange. High 
levels of market share enhance the value of trading and ports. Total 
contracts include both multi-list options and proprietary options 
products. Proprietary options products are products with 
intellectual property rights that are not multi-listed. Phlx lists 
proprietary products.

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[[Page 47101]]

[GRAPHIC] [TIFF OMITTED] TN30SE25.002

Top of Market Feed
    The Top of Market fees, which are not proposed to change from 
current levels, are comparable to, or less than, fees charged by Nasdaq 
ISE, Nasdaq GEMX and Nasdaq MRX based on relative market share.
    As explained above, the Exchange proposes to remove the reference 
to last sale information from TOPO and offer last sale information in a 
separate, standalone data feed, the Trades Feed, to align Phlx's feeds 
with the structure used by the Nasdaq ISE, GEMX and MRX exchanges.\28\ 
As stated above, Nasdaq proposes to offer the Trades Feed at no 
additional cost with the purchase of TOPO, and plans to propose a fee 
for the Trades Feed at a later date. Fees for the top of book feed are 
not proposed to change.
---------------------------------------------------------------------------

    \28\ Nasdaq ISE Top of Market Feed at Options 3, Section 
23(a)(3); Nasdaq GEMX Top of Market Feed at Options 3, Section 
23(a)(3); Nasdaq MRX Top Feed at Options 3, Section 23(a)(3).
---------------------------------------------------------------------------

    As noted above, changes are being proposed to the definition of the 
top of book feed for the ISE, GEMX and MRX exchanges to correct a 
technical error in the existing rule text.
    For ISE, the inadvertent error appears to have occurred in the 
context of the September 9, 2024 technology migration by ISE to 
implement enhanced functionality.\29\ While ISE's System was coded to 
remove the last sale information as well as order imbalance information 
on opening/reopening from the Top Feed, the Exchange inadvertently did 
not remove the corresponding last sale information and order imbalances 
information from the description of the feed content in Options 3, 
Section 23(a)(3) in its corresponding rule change. The market data 
specifications made available to subscribers were changed to reflect 
the last sale information and order imbalance information being removed 
at the time of each migration, which made subscribers aware of the 
changes.\30\
---------------------------------------------------------------------------

    \29\ See Securities Exchange Act Release No. 96818 (February 6, 
2023), 88 FR 8950 (February 10, 2023) (SR-ISE-2023-06) (Proposed 
Rule Change to Amend its Rules in Connection with a Technology 
Migration to Enhanced Nasdaq, Inc. Functionality).
    \30\ See MRX, GEMX and ISE Top of Market Feed Version 2.02, 
available at <a href="https://assets.ctfassets.net/mx0rke14e5yt/5OQgAZl7u0wZu6G8lnta06/ad706073750089976bce73aee8188fe2/ISE_GEMX_MRX_Top_of_Market_Feed.pdf">https://assets.ctfassets.net/mx0rke14e5yt/5OQgAZl7u0wZu6G8lnta06/ad706073750089976bce73aee8188fe2/ISE_GEMX_MRX_Top_of_Market_Feed.pdf</a>.
---------------------------------------------------------------------------

    A similar error occurred for GEMX in the context of the November 6, 
2023 technology migration to implement enhanced functionality.\31\ 
While GEMX's System was coded to remove the last sale information as 
well as order imbalance information on opening/reopening from the Top 
Feed, the Exchange inadvertently did not remove the corresponding last 
sale information and order imbalances information from the description 
of the feed content in Options 3, Section 23(a)(3) in its corresponding 
rule change. The market data specifications made available to 
subscribers were changed to reflect the last sale information and order 
imbalance information being removed at the time of each migration, 
which made subscribers aware of the changes.\32\
---------------------------------------------------------------------------

    \31\ See Securities Exchange Act Release No. 96817 (February 6, 
2023), 88 FR 8922 (February 10, 2023) (SR-GEMX-2023-02) (proposed 
change to amend rules in connection with the technology migration to 
enhanced Nasdaq functionality).
    \32\ See Supra note 30.
---------------------------------------------------------------------------

    A similar error occurred for MRX in the context of the November 7, 
2022 technology migration to implement enhanced functionality.\33\ 
While MRX's System was coded to remove the last sale information as 
well as order imbalance information on opening/reopening from the Top 
Feed, the Exchange inadvertently did not remove the corresponding last 
sale information and order imbalances information from the description 
of the feed content in Options 3, Section 23(a)(3) in its

[[Page 47102]]

corresponding rule change. The market data specifications made 
available to subscribers were changed to reflect the last sale 
information and order imbalance information being removed at the time 
of each migration, which made subscribers aware of the changes.\34\
---------------------------------------------------------------------------

    \33\ See Securities Exchange Act Release No. 95982 (October 4, 
2022), 87 FR 61391 (October 11, 2022) (SR-MRX-2022-18) (proposed 
rule changes in connection with technology migration to enhance 
functionality); see also Securities Exchange Act Release No. 96941 
(February 16, 2023), 88 FR 11490 (February 23, 2023) (SR-MRX-2023-
06) (implementing MRX market data fee changes).
    \34\ See Supra note 30.
---------------------------------------------------------------------------

    Although the contents of the top feeds changed in September 2024 
for ISE, November 2023 for GEMX, and December 2022 for MRX, the 
Exchange is aware of no customer that changed its behavior as a result 
of this change. As such, customers did not perceive a significant shift 
in the relative value of the data, and the fees for ISE, GEMX, and MRX 
are comparable to the top of book information proposed by Phlx both 
before and after the data feed change.
    The proposed fees for Phlx are comparable to, or less than, the 
fees charged by Nasdaq ISE, GEMX and MRX based on relative market 
share. The table below compares the proposed Phlx Top of Market Feed 
fees with those of ISE, GEMX and MRX.

----------------------------------------------------------------------------------------------------------------
                                            Market share
                 Exchange                        (%)                                Fees
----------------------------------------------------------------------------------------------------------------
Phlx.....................................             9.2  Internal Distributor: $2,500.
                                                           External Distributor: $3,000.
                                                           Non-Pro: $1.
                                                           Professional: $40.
ISE......................................             6.3  Professional (internal): $3,180.\35\
                                                           Professional (external): $3,180.
                                                           Internal and External: $3,180.
                                                           Non-Professional external distribution (controlled
                                                            device): $3,000.
GEMX.....................................             2.4  Professional (internal): $1,055.\36\
                                                           Professional (external): $1,055.
                                                           Professional (internal and external): $1,055.
                                                           Non-Professional external distribution (controlled
                                                            device): $1,000.
MRX......................................             2.5  Internal: $1,515.
                                                           External: $2,020.
                                                           Non-Pro: $1.
                                                           Professional: $25.25.
----------------------------------------------------------------------------------------------------------------

    ISE: The proposed (and current) fees for Phlx are less than or 
comparable to ISE fees for both internal and external distribution. 
Phlx proposes fees of $2,500 for internal distribution and $3,000 for 
external distribution. The proposed Phlx distribution fees are less 
than the ISE fees of $3,180 for internal distribution and $3,180 for 
external distribution.
---------------------------------------------------------------------------

    \35\ ISE Rulebook, Options 7, Section 10(H)
    \36\ GEMX Rulebook, Options 7, Section 7(B)
---------------------------------------------------------------------------

    The proposed (and current) Phlx fees for professional and non-
professional users are also less than or comparable to ISE fees. Phlx 
charges a variable fee of $40 for professionals and $1 for non-
professionals, while ISE charges a non-professional external 
distribution fee of $3,000 for non-professionals using a controlled 
device. Phlx's non-professional fees are below ISE fees for less than 
3,000 users. ISE does not charge professional user fees.
    Overall, the proposed Phlx fees are less than or comparable to the 
ISE fees, and reasonable given Phlx's market share of 9.2%, 
approximately 50 percent greater than ISE's market share of 6.3%.
    GEMX: The proposed (and current) fees for Phlx are comparable to 
GEMX fees for both internal and external distribution relative to 
market share. Phlx fees are $2,500 for internal distribution and $3,000 
for external distribution. While the Phlx fees are greater than the 
GEMX fees of $1,055 for internal distribution and $1,055 for external 
distribution, Phlx has a market share of 9.2%, nearly four times 
greater than GEMX's market share of 2.4%, and the fees are therefore 
comparable relative to market share.
    Phlx also charges a variable fee of $40 for professionals and $1 
for non-professionals; GEMX charges a non-professional external 
distribution fee of $1,000 for non-professionals using a controlled 
device that is not charged by Phlx. Phlx non-professional fees are 
lower than GEMX fees for fewer than 1,000 users. GEMX does not charge a 
professional user fee. Overall, the proposed Phlx fees are less than or 
comparable to GEMX fees, and reasonable given Phlx's market share of 
9.2%, approximately four times greater than GEMX's market share of 
2.4%.
    MRX: The proposed (and current) fees for Phlx are comparable to MRX 
fees for both internal and external distribution relative to market 
share. Phlx fees are $2,500 for internal distribution and $3,000 for 
external distribution. While the Phlx fees are greater than the MRX 
fees of $1,515 for internal distribution and $2,020 for external 
distribution, Phlx has a market share of 9.2%, nearly four times 
greater than MRX's market share of 2.5%, and the fees are therefore 
comparable relative to market share.
    Phlx also charges a variable fee of $40 for professionals and $1 
for non-professionals; MRX charges a non-professional subscriber fee of 
$25.25 for professionals and $1 for non-professionals. MRX's 
Professional and Non-Professional charges cover the usage of all five 
MRX data products and are not assessed separately for each data 
product.\37\ Overall, the proposed Phlx fees are comparable to MRX 
fees, and reasonable given Phlx's market share of 9.2%, approximately 
four times greater than GEMX's market share of 2.5%.
---------------------------------------------------------------------------

    \37\ MRX data is comprised of Depth of Market, Order, Top of 
Market, Trades, and Spread data. If a firm has one Professional 
(Non-Professional) Subscriber accessing Top of Market, Order, and 
Depth of Market the firm would only report the Subscriber once and 
pay $25 ($1 for Non-Professional).
---------------------------------------------------------------------------

Phlx Order Feed
    The proposed (and current) fees for the Phlx Order Feed are 
comparable to, or less than, fees charged by Nasdaq ISE,\38\ Nasdaq 
GEMX \39\ and Nasdaq MRX \40\ based on relative market share.
---------------------------------------------------------------------------

    \38\ Nasdaq ISE Rulebook, Options 7, Section 10(G).
    \39\ GEMX Rulebook, Options 7, Section 7(A).
    \40\ MRX Rulebook, Options 7, Section 7.
---------------------------------------------------------------------------

    As explained above, the Exchange proposes to remove complex order 
details from the Order Feed, but will offer such information free of 
charge on the Spread Feed with the purchase of an Order Feed 
subscription. Such information is not currently available on the Order 
Feeds of the Nasdaq ISE, Nasdaq GEMX and Nasdaq MRX exchanges, and 
therefore the proposed

[[Page 47103]]

feeds are comparable to the feeds of these other exchanges.
    The proposed fees for the Phlx Order Feed are comparable to, or 
less than, fees charged by Nasdaq ISE, Nasdaq GEMX and Nasdaq MRX 
exchanges based on relative market share. The table below compares the 
proposed Phlx Order Feed fees with those of ISE, GEMX and MRX.

----------------------------------------------------------------------------------------------------------------
                                            Market share
                 Exchange                        (%)                                Fees
----------------------------------------------------------------------------------------------------------------
Phlx.....................................             9.2  Internal Distributor: $3,500.
                                                           External Distributor: $4,000.
                                                           Non-Pro: $1
                                                           Professional: $40.
ISE......................................             6.3  Internal only: $3,150.
                                                           External distribution: $3,150.
                                                           Internal and External: $3,150.
MRX......................................             2.5  Internal: $1,515.
                                                           External: $2,020.
GEMX.....................................             2.4  Internal only: $790.
                                                           External: $790.
                                                           Internal and External: $790.
----------------------------------------------------------------------------------------------------------------

    ISE: The current and proposed fees for the Phlx Order Feed are 
comparable to those of ISE based on market share. Phlx proposes fees of 
$3,500 for internal distribution and $4,000 for external distribution, 
along with Non-Professional fees of $1 per user and Professional fees 
of $40 per user. While this is greater than the ISE fees of $3,150 for 
internal distribution and $3,150 for external or internal and external 
distribution, Phlx's market share of 9.2% is nearly 50 percent greater 
than ISE's market share of 6.3%, and the fees are therefore comparable.
    MRX: The current and proposed fees for the Phlx Order Feed are 
comparable to the MRX exchange fees based on market share. The proposed 
Phlx fees of $3,500 for internal distribution and $4,000 for external 
distribution, plus $1 for Non-Professional users and $40 per 
Professional users, are greater than the MRX fees of $1,515 per month 
for internal distribution and $2,020 per month for external 
distribution. Phlx's market share of 9.2%, however, is nearly four 
times greater than MRX's market share of 2.5%, and the fees are 
therefore comparable.
    GEMX: The current and proposed fees for the Phlx Order Feed are 
comparable to the comparable GEMX fees based on market share. The 
proposed Phlx fees of $3,500 for internal distribution and $4,000 for 
external distribution, plus $1 for Non-Professional users and $40 per 
Professional users, are greater than the GEMX fees of $790 per month 
for internal distribution and $790 per month for external distribution 
or internal and external distribution. However, Phlx's market share of 
9.2% is nearly four times greater than GEMX's market share of 2.4%, and 
the fees are therefore comparable relative to market share.
Phlx Depth Fees
    The proposed (and current) fees for the Phlx Depth Feed are 
comparable to, or less than, fees charged by Nasdaq ISE,\41\ Nasdaq 
GEMX \42\ and Nasdaq MRX \43\ based on relative market share.
---------------------------------------------------------------------------

    \41\ Nasdaq ISE Rulebook, Options 7, Section 10(F).
    \42\ GEMX Rulebook, Options 7, Section 7(C).
    \43\ MRX Rulebook, Options 7, Section 7(1)

----------------------------------------------------------------------------------------------------------------
                                            Market share
                 Exchange                        (%)                                Fees
----------------------------------------------------------------------------------------------------------------
Phlx.....................................             9.2  Internal Distributor: $4,232.
                                                           External Distributor: $4,760.
                                                           Non-Pro: $1.
                                                           Pro: $42.30.
ISE......................................             6.3  Internal only: $5,300.
                                                           External distribution: $5,300.
                                                           Non-Professional (controlled device): $5,000.
MRX......................................             2.5  Internal: $1,515.
                                                           External: $2,020.
GEMX.....................................             2.4  Internal only: $1,580.
                                                           External: $1,580.
                                                           Non-Professional: $1,500.
                                                           Per Controlled Device: $1.
----------------------------------------------------------------------------------------------------------------

    ISE: The current and proposed fees for the Phlx Depth Feed are less 
than those of ISE based on market share. Phlx proposes fees of $4,232 
for internal distribution and $4,760 for external distribution, along 
with Non-Professional fees of $1 per user and Professional fees of 
$42.30 per user. These are less than the fees charged by ISE: $5,300 
for internal distribution, $5,300 for external distribution, and $5,000 
for non-professional distribution on a controlled device. As the 
proposed Phlx fees are less than ISE fees, notwithstanding the greater 
market share, the proposed fees are reasonable.
    MRX: The current and proposed fees for the Phlx Depth Feed are 
comparable to the MRX exchange fees based on market share. Phlx 
proposes fees of $4,232 for internal distribution and $4,760 for 
external distribution, along with Non-Professional fees of $1 per user 
and Professional fees of $42.30 per user. While these fees are greater 
than the MRX fees of $1,515 per month for internal distribution and 
$2,020 per month for external distribution, Phlx's market share of 9.2% 
is nearly four times greater than MRX's market share

[[Page 47104]]

of 2.5%, and the fees are therefore comparable.
    GEMX: The current and proposed fees for the Phlx Depth Feed are 
comparable to the comparable GEMX fees based on market share. Phlx 
proposes fees of $4,232 for internal distribution and $4,760 for 
external distribution, along with Non-Professional fees of $1 per user 
and Professional fees of $42.30 per user. While these fees are greater 
than the GEMX fees of $1,580 per month for internal distribution, 
$1,580 per month for external distribution, $1,500 for non-professional 
distribution, and $1 per controlled device, Phlx's market share of 9.2% 
is nearly four times greater than GEMX's market share of 2.4%, and the 
fees are therefore comparable relative to market share.
Nasdaq Phlx Spread Feed Fees
    Nasdaq proposes no additional fees for the Spread Feed, but rather 
will offer the Spread Feed at no cost with the purchase of the Order 
Feed. This will allow market participants to obtain both simple and 
complex order information for a single fee. Nasdaq will propose a 
separate fee for the purchase of the Order Feed at a later date.
Trades Feed
    Nasdaq proposes no additional fees for the Trades Feed, but rather 
will offer the Trades Feed at no cost with the purchase of TOPO. This 
will allow market participants to obtain both top of book information 
and trades information for a single fee. Nasdaq will propose a separate 
fee for the purchase of the Trades Feed at a later date.

B. Self-Regulatory Organization's Statement on Burden on Competition

    The Exchange does not believe that the proposed rule change will 
impose any burden on competition not necessary or appropriate in 
furtherance of the purposes of the Act.
Market Data Definitions
    The Exchange's proposal to align its existing market data feeds 
(TOPO, Phlx Order Feed, and Phlx Depth of Market) to ISE's Market Data 
Feeds (ISE Depth of Market Data Feed, ISE Order Feed, and ISE Top of 
Market Feed) and adopt two other feeds (Phlx Trades Feed and Phlx 
Spread Feed) which are identical to ISE feeds (ISE Trades Feed, and ISE 
Spread Feed) does not impose an undue burden on intra-market 
competition, rather it provides Phlx member and member organization 
access to an equivalent amount of data currently available on ISE. All 
Phlx members and member organizations may subscribe to these feeds.
    The Exchange's proposal to align its existing market data feeds 
(TOPO, Phlx Order Feed, and Phlx Depth of Market) to ISE's Market Data 
Feeds (ISE Depth of Market Data Feed, ISE Order Feed, and ISE Top of 
Market Feed) and adopt two other feeds (Phlx Trades Feed and Phlx 
Spread Feed) which are identical to ISE feeds (ISE Trades Feed, and ISE 
Spread Feed) does not impose an undue burden on inter-market as other 
options markets may elect to offer similar feeds.
Fees
    Nothing in the proposal burdens inter-market competition (the 
competition among self-regulatory organizations) because approval of 
the Proposal does not impose any burden on the ability of other options 
exchanges to compete. As explained above, Nasdaq proposes no additional 
fees for the Trades or Spread feeds, but rather will offer both at no 
cost with the purchase of the TOPO or Order Feed, respectively. As 
such, the proposed fees for the Spread Feed and the Trades Feed are 
comparable to, and in some cases less than when compared to market 
share, those of other exchanges, as discussed above.
    Nothing in the Proposal burdens intra-market competition (the 
competition among consumers of exchange data) because the Spread Feed 
and the Trades Feed are available to any market participant at the same 
price and any market participant that elects to purchase either the 
Spread Feed or the Trades Feed may do so on a non-discriminatory basis.

C. Self-Regulatory Organization's Statement on Comments on the Proposed 
Rule Change Received From Members, Participants, or Others

    No written comments were either solicited or received.

III. Date of Effectiveness of the Proposed Rule Change and Timing for 
Commission Action

    Because the foregoing proposed rule change does not: (i) 
significantly affect the protection of investors or the public 
interest; (ii) impose any significant burden on competition; and (iii) 
become operative for 30 days from the date on which it was filed, or 
such shorter time as the Commission may designate, it has become 
effective pursuant to Section 19(b)(3)(A)(iii) of the Act \44\ and 
subparagraph (f)(6) of Rule 19b-4 thereunder.\45\
---------------------------------------------------------------------------

    \44\ 15 U.S.C. 78s(b)(3)(A)(iii).
    \45\ 17 CFR 240.19b-4(f)(6). In addition, Rule 19b-4(f)(6) 
requires a self-regulatory organization to give the Commission 
written notice of its intent to file the proposed rule change at 
least five business days prior to the date of filing of the proposed 
rule change, or such shorter time as designated by the Commission. 
The Exchange has satisfied this requirement.
---------------------------------------------------------------------------

    At any time within 60 days of the filing of the proposed rule 
change, the Commission summarily may temporarily suspend such rule 
change if it appears to the Commission that such action is necessary or 
appropriate in the public interest, for the protection of investors, or 
otherwise in furtherance of the purposes of the Act. If the Commission 
takes such action, the Commission shall institute proceedings to 
determine whether the proposed rule should be approved or disapproved.

IV. Solicitation of Comments

    Interested persons are invited to submit written data, views and 
arguments concerning the foregoing, including whether the proposed rule 
change is consistent with the Act. Comments may be submitted by any of 
the following methods:

Electronic Comments

    <bullet> Use the Commission's internet comment form (<a href="https://www.sec.gov/rules/sro.shtml">https://www.sec.gov/rules/sro.shtml</a>); or
    <bullet> Send an email to <a href="/cdn-cgi/l/email-protection#b3c1c6dfd69ed0dcdeded6ddc7c0f3c0d6d09dd4dcc5"><span class="__cf_email__" data-cfemail="6d1f180108400e0200000803191e2d1e080e430a021b">[email&#160;protected]</span></a>. Please include 
file number SR-Phlx-2025-53 on the subject line.

Paper Comments

    <bullet> Send paper comments in triplicate to Secretary, Securities 
and Exchange Commission, 100 F Street NE, Washington, DC 20549-1090.

All submissions should refer to file number SR-Phlx-2025-53. This file 
number should be included on the subject line if email is used. To help 
the Commission process and review your comments more efficiently, 
please use only one method. The Commission will post all comments on 
the Commission's internet website (<a href="https://www.sec.gov/rules/sro.shtml">https://www.sec.gov/rules/sro.shtml</a>). Copies of the filing will be available for inspection and 
copying at the principal office of the Exchange. Do not include 
personal identifiable information in submissions; you should submit 
only information that you wish to make available publicly. We may 
redact in part or withhold entirely from publication submitted material 
that is obscene or subject to copyright protection. All submissions 
should refer to file number SR-Phlx-2025-53 and should be submitted on 
or before October 21, 2025.


[[Page 47105]]


    For the Commission, by the Division of Trading and Markets, 
pursuant to delegated authority.\46\
---------------------------------------------------------------------------

    \46\ 17 CFR 200.30-3(a)(12).
---------------------------------------------------------------------------

Sherry R. Haywood,
Assistant Secretary.
[FR Doc. 2025-18939 Filed 9-29-25; 8:45 am]
BILLING CODE 8011-01-P


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