February 26, 2007

Nancy M. Morris
Secretary, Securities and Exchange Commission
100 F. Street, NE
Washington, DC 20549-1090

re: SR-CBOE-2006-106

Dear Ms. Morris:

My name is John Pietrzak and I have been a member of the Chicago Board of Trade (CBOT) since 1979 and of the Chicago Board Options Exchange (CBOE) by way of exercising my CBOT/CBOE membership right, since 1987. By way of further background, I currently serve on the board of directors of the Chicago Board of Trade and its parent, CBOT Holdings.

Since the year 2000, I have been an active partner in Sparta Group, a proprietary trading group whose principal place of business is the CBOE. As a businessman, I have counted on unfettered access to the CBOE and its markets by way of my CBOT/CBOE exercise right. Additionally, I own a second CBOT seat which is also exercised on the CBOE by Timberhill/Interactive Brokers, who for the last 24 years have also counted on access to the CBOE markets by way of the CBOT/CBOE exercise right. I firmly believe that the rule change which is proposed to affect the exercise right granted under Article Fifth(b) is capricious and a blatant attempt by CBOE leadership to enrich one class of member at the expense of another. The CBOE has functioned in a superior manner as a marketplace for more than 25 years with the CBOT exercise members as significant contributors to liquidity and profitability. It is impossible to imagine in what manner these changes in corporate structure would have an adverse effect on the continued functioning of the CBOE as a premier marketplace. More to the contrary, I believe that granting this rule change request would have an immediate negative impact on the functioning of the CBOE markets.

I hereby request that you reject the CBOE request for a rule change which seems nothing more than a modern day land-grab prior to their proposed restructuring and IPO.


John L. Pietrzak