From: William H. Cournoyer
Sent: February 10, 2007
Subject: File No. SR-CBOE-2006-106

I am opposed to the CBOE's proposed rule change SR-CBOE-2006-106.

I have been a full member of the CBOT since 1977 and have been contractually entitled to the right to be an exercise member (with all the rights that such a membership conveys to me) at the CBOE since that time. There is no dispute of this fact.

The rule change is an attempt by the CBOE to eliminate its obligation to me without consideration or compensation. The sole purpose of this rule is to eliminating an entire class of founding members for the enrichment of another group of members. This is not an issue of providing open and transparent public markets.

With reasonable consideration for progress in the evolution of our public exchanges, I have been and will remain a full member with the required equity and trading privileges as spelled out in the CBOE charter document and as a result am entitled to all of the inherent rights thereof.

William H. Cournoyer