[Federal Register Volume 89, Number 59 (Tuesday, March 26, 2024)]
[Notices]
[Pages 21099-21104]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2024-06324]
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SECURITIES AND EXCHANGE COMMISSION
[Release No. 34-99787; File No. SR-GEMX-2024-07]
Self-Regulatory Organizations; Nasdaq GEMX, LLC; Notice of Filing
and Immediate Effectiveness of Proposed Rule Change To Amend Options 7,
Section 6
March 20, 2024.
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 March 7, 2024, Nasdaq GEMX, LLC (``GEMX'' 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 its Rules at Options 7, Section 6,
C, Ports and Other Services.\3\
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\3\ The Exchange initially filed the proposed pricing changes on
November 28, 2023 (SR-GEMX-2023-16) to be effective on December 1,
2023. On December 5, 2023, the Exchange withdrew SR-GEMX-2023-16 and
replaced it with SR-GEMX-2023-19. On January 16, 2023, the Exchange
withdrew SR-GEMX-2023-19 and submitted SR-GEMX-2024-03. On March 7,
2024, the Exchange withdrew SR-GEMX-2024-03 and submitted this
filing.
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The text of the proposed rule change is available on the Exchange's
website at https://listingcenter.nasdaq.com/rulebook/gemx/rules, at the
principal
[[Page 21100]]
office of the Exchange, and at the Commission's Public Reference Room.
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
The Exchange proposes to amend Options 7, Section 6, C, Ports and
Other Services. Specifically, the Exchange proposes to amend the
monthly caps for SQF Ports \4\ and SQF Purge Ports.\5\
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\4\ ``Specialized Quote Feed'' or ``SQF'' is an interface that
allows Market Makers to connect, send, and receive messages related
to quotes, Immediate-or-Cancel Orders, and auction responses to the
Exchange. Features include the following: (1) options symbol
directory messages (e.g., underlying instruments); (2) System event
messages (e.g., start of trading hours messages and start of
opening); (3) trading action messages (e.g., halts and resumes); (4)
execution messages; (5) quote messages; (6) Immediate-or-Cancel
Order messages; (7) risk protection triggers and purge
notifications; (8) opening imbalance messages; (9) auction
notifications; and (10) auction responses. The SQF Purge Interface
only receives and notifies of purge requests from the Market Maker.
Market Makers may only enter interest into SQF in their assigned
options series. Immediate-or-Cancel Orders entered into SQF are not
subject to the Order Price Protection, Market Order Spread
Protection, and Size Limitation Protection in Options 3, Section
15(a)(1)(A), (1)(B), and (2)(B) respectively. See Supplementary
Material .03(c) to Options 3, Section 7.
\5\ SQF Purge is a specific port for the SQF interface that only
receives and notifies of purge requests from the Market Maker.
Dedicated SQF Purge Ports enable Market Makers to seamlessly manage
their ability to remove their quotes in a swift manner. The SQF
Purge Port is designed to assist Market Makers in the management of,
and risk control over, their quotes. Market Makers may utilize a
purge port to reduce uncertainty and to manage risk by purging all
quotes in their assigned options series. Of note, Market Makers may
only enter interest into SQF in their assigned options series.
Additionally, the SQF Purge Port may be utilized by a Market Maker
in the event that the Member has a system issue and determines to
purge its quotes from the order book.
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Today, GEMX assesses $1,250 per port, per month for an SQF Port as
well as an SQF Purge Port.\6\ Also, today, SQF Ports and SQF Purge
Ports are subject to a monthly cap of $17,500, which cap is applicable
to Market Makers.
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\6\ The Exchange proposes to add a comma between ``per port''
and ``per month'' in the Options 7, Section 6, C, SQF Port and SQF
Purge Port Fee rule text. The Exchange also proposes to remove an
extraneous period in Options 7, Section 6, C, in the second
paragraph.
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At this time, the Exchange proposes to increase the SQF Port and
SQF Purge Port monthly cap fee of $17,500 per month to $27,500 per
month.\7\ The Exchange is not amending the $1,250 per port, per month
SQF Port and SQF Purge Port. As is the case today, the Exchange would
not assess a Member an SQF Port or SQF Purge Port fee beyond the
monthly cap once the Member has exceeded the monthly cap for the
respective month.
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\7\ Today, 62% of GEMX Market Makers have capped their SQF Ports
and SQF Purge Ports on GEMX. The Exchange notes that of the Market
Makers currently registered on GEMX, there is a mix of size of
Market Makers that cap.
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Despite increasing the monthly cap for SQF Ports and SQF Purge
Ports from $17,500 per month to $27,500 per month, the Exchange will
continue to offer Members the opportunity to cap their SQF Port and SQF
Purge Port fees so that they would not be assessed these fees beyond
the cap.
Pursuant to Supplementary Material .03(c) to Options 3, Section 7,
Market Makers may only enter interest into SQF in their assigned
options series. Pursuant to Supplementary Material .03(c) to Options 3,
Section 7, the SQF interface allows Market Makers to connect, send, and
receive messages related to quotes, Immediate-or-Cancel Orders, and
auction responses to the Exchange. A GEMX Market Maker requires only
one SQF Port to submit quotes in its assigned options series into GEMX.
An SQF Purge is a specific port for the SQF interface that only
receives and notifies of purge requests from the Market Maker. A GEMX
Market Maker may submit all quotes through one SQF Port and utilize one
SQF Purge Port to view its purge requests. While a Market Maker may
elect to obtain multiple SQF Ports and SQF Purge Ports to organize its
business,\8\ only one SQF Port and SQF Purge Port is necessary for a
Market Maker to fulfill its regulatory quoting obligations.\9\
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\8\ For example, a Market Maker may desire to utilize multiple
SQF Ports for accounting purposes, to measure performance, for
regulatory reasons or other determinations that are specific to that
Member.
\9\ GEMX Market Makers have various regulatory requirements as
provided for in Options 2, Section 4. Additionally, GEMX Market
Makers have certain quoting requirements with respect to their
assigned options series as provided in Options 2, Section 5. SQF
Ports are the only quoting protocol available on GEMX and only
Market Makers may utilize SQF Ports. The same is true for SQF Purge
Ports.
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2. Statutory Basis
The Exchange believes that its proposal is consistent with Section
6(b) of the Act,\10\ in general, and furthers the objectives of
Sections 6(b)(4) and 6(b)(5) of the Act,\11\ 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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\10\ 15 U.S.C. 78f(b).
\11\ 15 U.S.C. 78f(b)(4) and (5).
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The proposed pricing change to increase the SQF Port and SQF Purge
Port monthly cap from $17,500 per month to $27,500 per month is
reasonable because despite the increase in the monthly cap, the
Exchange will continue to offer Members the opportunity to cap their
SQF Port and SQF Purge Port fees so that they would not be assessed
these fees beyond the cap. Additionally, a GEMX Market Maker requires
only one SQF Port to submit quotes in its assigned options series into
GEMX. A GEMX Market Maker may submit all quotes through one SQF Port
and utilize one SQF Purge Port to view its purge requests. While a
Market Maker may elect to obtain multiple SQF Ports and SQF Purge Ports
to organize its business,\12\ only one SQF Port and SQF Purge Port is
necessary for a Market Maker to fulfill its regulatory quoting
obligations.\13\ Members may choose a greater number of SQF Ports or
SQF Purge Ports, beyond one port, depending on that Member's particular
business model. Additionally, the Exchange believes that the caps are
reasonable for two reasons.
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\12\ For example, a Market Maker or may desire to utilize
multiple SQF Ports for accounting purposes, to measure performance,
for regulatory reasons or other determinations that are specific to
that Member.
\13\ GEMX Market Makers have various regulatory requirements as
provided for in Options 2, Section 4. Additionally, GEMX Market
Makers have certain quoting requirements with respect to their
assigned options series as provided in Options 2, Section 5. SQF
Ports are the only quoting protocol available on GEMX and only
Market Makers may utilize SQF Ports.
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First, SQF Ports are a secure method for Market Makers to submit
quotes into the Exchange's match engine and for the Exchange to send
messages related to those quotes to Market Makers. GEMX must manage the
security and message traffic, among other things, for each port.
Utilizing the cap to manage a Market Maker's costs while also managing
the quantity of SQF Ports issued on GEMX has led the Exchange to select
$27,500 as the amended monthly cap for SQF Ports and SQF
[[Page 21101]]
Purge Ports. By capping the ports at a different level, the Exchange is
considering the message traffic and message rates associated with the
current number of outstanding ports and its ability to process
messages. The ability to have a cap and amend that cap permits the
Exchange to scale its needs with respect to processing messages in an
efficient manner. The Exchange notes that Cboe Exchange, Inc.
(``Cboe'') limits usage on each port and assesses fees for incremental
usage.\14\
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\14\ Each Cboe Binary Order Entry (``BOE'') or FIX Logical Port
incur the logical port fee indicated when used to enter up to 70,000
orders per trading day per logical port as measured on average in a
single month. For each incremental usage of up to 70,000 per day per
logical port will incur an additional logical port fee of $800 per
month. BOE or FIX Logical Ports provide users the ability to enter
order/quotes. See Cboe's Fees Schedule.
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Second, the Exchange notes that multiple ports are not necessary,
however, to the extent that some Market Makers elect to obtain multiple
ports, the Exchange is offering to cap their total port cost at $27,500
per month. GEMX believes the existence of a cap allows for efficiencies
and permits Market Makers to increase their number of ports beyond the
cap. The cap levels the playing field by allowing those Market Makers
that want to obtain a larger number of ports to do so with the
certainty of a fee cap. Without the cap, GEMX Market Makers may pay
more to obtain multiple ports on GEMX. BOX Exchange LLC (``BOX'')
assesses $1,000 per month for all SAIL Ports for Market Making and $500
per month per port up to 5 ports for order entry and $150 per month for
each additional port.\15\ MIAX's MIAX Express Interface (``MEI'') Fee
levels are based on a tiered fee structure based on the Market Maker's
total monthly executed volume during the relevant month.\16\
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\15\ See BOX's Fee Schedule.
\16\ MEI is a connection to MIAX systems that enables Market
Makers to submit simple and complex electronic quotes to MIAX. MIAX
caps its MEI Ports. For these Monthly MIAX MEI Fees levels, if the
Market Maker's total monthly executed volume during the relevant
month is less than 0.060% of the total monthly executed volume
reported by OCC in the market maker account type for MIAX-listed
option classes for that month, then the fee will be $14,500 instead
of the fee otherwise applicable to such level. See MIAX's Fee
Schedule.
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The number of ports that members choose to purchase varies widely.
Today, on GEMX, no Marker Makers have 1 SQF Port/SQF Purge Port, 1
Market Maker had 2-5 SQF Ports/SQF Purge Ports, 4 Market Makers have
between 6-10 SQF Ports/SQF Purge Ports, and 8 Market Makers have more
than 11 SQF Ports/SQF Purge Ports. The chart below represents the
number of SQF Ports and SQF Purge Ports that are subscribed to by
members across the six Nasdaq affiliated options markets.
[GRAPHIC] [TIFF OMITTED] TN26MR24.011
The Exchange's proposed pricing change to increase the SQF Port and
SQF Purge Port monthly cap from $17,500 per month to $27,500 per month
is equitable and not unfairly discriminatory because the Exchange would
uniformly not assess any Market Makers that exceeded the proposed
monthly cap any SQF Port and SQF Purge Port fees for that month beyond
the cap. Market Makers are the only market participants that are
assessed SQF Port and SQF Purge Port fees because they are the only
market participants that are permitted to quote on the Exchange. SQF
Ports and SQF Purge Ports are only utilized in the Market Maker's
assigned options series. The following chart represents the
classification of GEMX Members and the percentage of Market Makers.
[[Page 21102]]
[GRAPHIC] [TIFF OMITTED] TN26MR24.012
Unlike other market participants, Market Makers are subject to
market making and quoting obligations.\17\ These liquidity providers
are critical market participants in that they are the only market
participants that provide liquidity to GEMX on a continuous basis. In
addition, the Exchange notes that Lead Market Makers are required to
submit quotes in the Opening Process to open an options series.\18\
Market Makers are subject to a number of fees, unlike other market
participants. Market Makers pay separate Membership Fees,\19\ and CMM
Trading Right Fees,\20\ in addition to other fees paid by other market
participants. Providing Market Makers a means to cap their cost related
to quoting and enabling all Market Makers to acquire SQF Ports and SQF
Purge Ports at no cost beyond a certain dollar amount enables these
market participants to provide the necessary liquidity to GEMX at lower
costs. Therefore, because Market Makers fulfill a unique role on the
Exchange, are the only market participant required to submit quotes as
part of their obligations to operate on the Exchange, and, in light of
that role, they are eligible for certain incentives. The proposed SQF
Port and SQF Purge Fee cap is designed to continue to incent Market
Makers to quote on GEMX, thereby promoting liquidity, quote
competition, and trading opportunities.
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\17\ See Options 2, Sections 4 and 5.
\18\ See Options 3, Section 8.
\19\ See Options 7, Section 6, A.
\20\ See Options 7, Section 6, B.
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In 2022, NYSE Arca, Inc. (``NYSE Arca'') proposed to restructure
fees relating to OTPs for Market Makers.\21\ In that rule change,\22\
NYSE Arca argued that,
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\21\ See Securities Exchange Act Release No. 95412 (June 23,
2022), 87 FR 38786 (June 29, 2022) (SR-NYSEArca-2022-36). NYSE Arca
proposed to increase both the monthly fee per Market Maker OTP and
the number of issues covered by each additional OTP because, among
other reasons, the number of issues traded on the Exchange has
increased significantly in recent years.
\22\ Id at 38788.
Market Makers serve a unique and important function on the
Exchange (and other options exchanges) given the quote-driven nature
of options markets. Because options exchanges rely on actively
quoting Market Makers to facilitate a robust marketplace that
attracts order flow, options exchanges must attract and retain
Market Makers, including by setting competitive Market Maker permit
fees. Stated otherwise, changes to Market Maker permit fees can have
a direct effect on the ability of an exchange to compete for order
flow. The Exchange also believes that the number of options
exchanges on which Market Makers can effect option transactions also
ensures competition in the marketplace and constrains the ability of
exchanges to charge supracompetitive fees for access to its market
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by Market Makers.
Further, NYSE ARCA noted that,\23\
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\23\ Id at 38790.
The Exchange further believes that its ability to set Market
Maker permit fees is constrained by competitive forces based on the
fact that Market Makers can, and have, chosen to terminate their
status as a Market Maker if they deem Market Maker permit fees to be
unreasonable or excessive. Specifically, the Exchange notes that a
BOX participant modified its access to BOX in connection with the
implementation of a proposed change to BOX's Market Maker permit
fees. The Exchange has also observed that another options exchange
group experienced decreases in market share following its proposed
modifications of its access fees (including Market Maker trading
permit fees), suggesting that market participants (including Market
Makers) are sensitive to changes in exchanges' access fees and may
respond by shifting their order flow elsewhere if they deem the fees
to be unreasonable or excessive.
There is no requirement, regulatory or otherwise, that any
Market Maker connect to and access any (or all of) the available
options exchanges. The Exchange also is not aware of any reason why
a Market Maker could not cease being a permit holder in response to
unreasonable price increases. The Exchange does not assess any
termination fee for a Market Maker to drop its OTP, nor is the
Exchange aware of any other costs that would be incurred by a Market
Maker to do so.
The Exchange likewise believes that its ability to cap SQF Port and
SQF Purge fees is constrained by competitive forces and that its
proposed modifications to the SQF Port and SQF Purge Fee cap is
reasonably designed in consideration of the competitive environment in
which the Exchange operates, by balancing the value of the enhanced
benefits available to Market Makers due to the current level of
activity on the Exchange with a fee structure that will continue to
incent Market Makers to support increased
[[Page 21103]]
liquidity, quote competition, and trading opportunities on the
Exchange, for the benefit of all market participants.
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.
Intermarket Competition
The proposal does not impose an undue burden on intermarket
competition. The Exchange believes its proposal remains competitive
with other options markets who also offer order entry protocols. The
Exchange notes that it operates in a highly competitive market in which
market participants can readily favor competing venues if they deem fee
levels at a particular venue to be excessive. The chart below shows the
February 2024 market share for multiply listed options by exchange. Of
the 17 operating options exchanges, none currently has more than a
17.6% market share. Customers widely distribute their transactions
across exchanges according to their business needs and the ability of
each exchange to meet those needs through technology, liquidity and
functionality.
[GRAPHIC] [TIFF OMITTED] TN26MR24.013
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.
In such an environment, the Exchange must continually adjust its
fees to remain competitive with other exchanges. Because competitors
are free to modify their own fees in response, and because market
participants may readily adjust their order routing practices, the
Exchange believes that the degree to which fee changes in this market
may impose any burden on competition is extremely limited.
Other exchanges amended certain costs attributed to Market
Makers.\24\ In 2022, MRX proposed a monthly cap for SQF Ports and SQF
Purge Ports of 17,500.\25\ MRX noted in its rule change that, ``Only
one SQF quote protocol is required for an MRX Market Maker to submit
quotes into MRX and to meet its regulatory requirements.'' \26\
Additionally, BOX Exchange LLC (``BOX'') assesses $1,000 per month for
all SAIL Ports for Market Making and $500 per month per port up to 5
ports for order entry and $150 per month for each additional port.\27\
MIAX's MIAX Express Interface (``MEI'') Fee levels are based on a
tiered fee structure based on the Market Maker's total monthly executed
volume during the relevant month.\28\
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\24\ See Securities Exchange Act Release No. 95412 (June 23,
2022), 87 FR 38786 (June 29, 2022) (SR-NYSEArca-2022-36).
\25\ See Securities Exchange Act No. 96824 (February 7, 2023),
88 FR 8975 (February 10, 2023) (SR-MRX-2023-05) (Notice of Filing
and Immediate Effectiveness of Proposed Rule Change To Amend MRX
Options 7, Section 6).
\26\ Id at 8976.
\27\ See BOX's Fee Schedule.
\28\ MEI is a connection to MIAX systems that enables Market
Makers to submit simple and complex electronic quotes to MIAX. MIAX
caps its MEI Ports. For these Monthly MIAX MEI Fees levels, if the
Market Maker's total monthly executed volume during the relevant
month is less than 0.060% of the total monthly executed volume
reported by OCC in the market maker account type for MIAX-listed
option classes for that month, then the fee will be $14,500 instead
of the fee otherwise applicable to such level. See MIAX's Fee
Schedule.
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If the Commission were to apply a different standard of review this
proposal than it applied to other exchange fee filings, where Market
Maker fees were increased and port fee caps were established, it would
create a burden on competition such that it would impair GEMX's ability
to compete among other options markets.
Intramarket Competition
The Exchange's proposed pricing change to increase the SQF Port and
SQF Purge Port monthly cap from $17,500 per month to $27,500 per month
does not impose an undue burden on competition because the Exchange
would uniformly not assess any Market Makers that exceeded the proposed
monthly cap any SQF Port and SQF Purge Port fees for that month beyond
the cap. Market Makers are the only market participants that are
assessed SQF Port and SQF Purge Port fees because they are the only
market
[[Page 21104]]
participants that are permitted to quote on the Exchange. SQF Ports and
SQF Purge Ports are only utilized in the Market Maker's assigned
options series. Unlike other market participants, Market Makers are
subject to market making and quoting obligations.\29\ These liquidity
providers are critical market participants in that they are the only
market participants that provide liquidity to GEMX on a continuous
basis. In addition, the Exchange notes that Lead Market Makers are
required to submit quotes in the Opening Process to open an options
series.\30\ Market Makers are subject to a number of fees, unlike other
market participants. Market Makers pay separate Membership Fees,\31\
and CMM Trading Right Fees,\32\ in addition to other fees paid by other
market participants. Providing Market Makers a means to cap their cost
related to quoting and enabling all Market Makers to acquire SQF Ports
and SQF Purge Ports at no cost beyond a certain dollar amount enables
these market participants to provide the necessary liquidity to GEMX at
lower costs. Therefore, because Market Makers fulfill a unique role on
the Exchange, are the only market participant required to submit quotes
as part of their obligations to operate on the Exchange, and, in light
of that role, they are eligible for certain incentives. The proposed
SQF Port and SQF Purge Fee cap is designed to continue to incent Market
Makers to quote on GEMX, thereby promoting liquidity, quote
competition, and trading opportunities.
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\29\ See Options 2, Sections 4 and 5.
\30\ See Options 3, Section 8.
\31\ See Options 7, Section 6, A.
\32\ See Options 7, Section 6, B.
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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
The foregoing rule change has become effective pursuant to Section
19(b)(3)(A)(ii) of the Act.\33\ 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: (i) necessary or appropriate in the public
interest; (ii) for the protection of investors; or (iii) 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.
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\33\ 15 U.S.C. 78s(b)(3)(A)(ii).
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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
Use the Commission's internet comment form (https://www.sec.gov/rules/sro.shtml); or
Send an email to [email protected]. Please include
file number SR-GEMX-2024-07 on the subject line.
Paper Comments
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-GEMX-2024-07. 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 (https://www.sec.gov/rules/sro.shtml). Copies of the submission, all subsequent amendments, all
written statements with respect to the proposed rule change that are
filed with the Commission, and all written communications relating to
the proposed rule change between the Commission and any person, other
than those that may be withheld from the public in accordance with the
provisions of 5 U.S.C. 552, will be available for website viewing and
printing in the Commission's Public Reference Room, 100 F Street NE,
Washington, DC 20549, on official business days between the hours of 10
a.m. and 3 p.m. Copies of the filing also 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-GEMX-2024-07 and should be
submitted on or before April 16, 2024.
For the Commission, by the Division of Trading and Markets,
pursuant to delegated authority.\34\
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\34\ 17 CFR 200.30-3(a)(12).
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Sherry R. Haywood,
Assistant Secretary.
[FR Doc. 2024-06324 Filed 3-25-24; 8:45 am]
BILLING CODE 8011-01-P