FOOTNOTE 18 Latency means "the time it takes to learn about an event (e.g., a change in the bid), generate a response, and have the exchange act on the response."
FOOTNOTE 20 See IntercontinentalExchange, "2010 Annual Report," at 26, available at http://files.shareholder.com/downloads/ICE/1747226327x0x456112/BF6F428C-F8B3-4835-B22C-3F350FF13B89/ICE_2010AR.pdf.
FOOTNOTE 21 See Matthew Philips, "Stock Trading is About to Get 5.2 Milliseconds Faster," BloombergBusinessweek (
FOOTNOTE 22 See Jacob Bunge, "CME, Nasdaq Plan High-Speed Network Venture,"
Two common methods for reducing latency are co-location and proximity hosting, defined as the placement of a firm's trading technology in close proximity to the trading platform. They may be offered directly by an exchange or by a third-party service provider. Co-location denotes those connectivity solutions hosted by the exchange itself, while proximity hosting indicates services offered by third parties. /23/ In 2010, the Commission published in the
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