From: Richard Friedman
Sent: February 13, 2007
To: rule-comments@sec.gov
Subject: File No. SR-CBOE-2006-106


To Whom It May Concern:

I believe that the CBOE’S attempt to extinguish the CBOT’S members’ rights is wrong and unjust. I have been trading for over 8 years, and 4 of those years I traded on the Chicago Board of Options Exchange’s floor as a member of the CBOT. If they would allow us to trade and pay them their commissions why would they not allow us to participate in a demutualization? We (CBOT) started the CBOE and under the contract signed by all parties involve gives us (members of the CBOT) all full rights and privileges as any member would receive at the CBOE. The CBOE’S attempt to make any changes is just another way so they would not have to give us any compensation, and to only help their own members at the expense of the full members at the CBOT. An agreement is an agreement and nothing should be changed in the favor of the CBOE…especially if there is not to be any compensation for the full members at the CBOT.

Sincerely,

Richard Friedman