From: Robert E. Otter
Sent: February 27, 2007
To: rule-comments@sec.gov
Subject: File No. SR-CBOE-2006-106


My name is Robert Otter and I wish to express my strong opposition to the CBOEs proposed rule change that is before you.

It is indisputable that the CBT founded the CBOE and embedded the rights of membership within its offspring for CBT full members. It is also indisputable that the price value of the two exchange memberships has been intertwined since the mid 1970s, indicating that the ownership rights of membership were also interconnected. Lastly and most tellingly, the CBOE itself has admitted that CBT members have an ownership stake in it by the fact that the CBOE bought 67 CBOE Exerciser Rights for the price of $100,000 each from CBT members in the spring of 2005. By doing this they were clearly admitting that CBT members had an ownership stake in the CBOE.

The dispute that exists between the CBOE and the CBT would ideally be settled between the parties through negotiation. If this fails the courts are clearly the proper way to decide this disagreement between the two institutions.

Please allow the two institutions to settle their dispute between themselves, whether this is through negotiation or through the courts.

Respectfully submitted,

Robert E. Otter