From: John V. Grimes
Sent: February 15, 2007
Subject: File No. SR-CBOE-2006-106

To whom it may concern, I am a Full member at the CBOT and I'd like to point out two issues concerning the CBOE's attempt to absolve the exercise rights. First the CBOE has benefitted both monetarily and image-wise in their connection to the CBOT. As volume is the life blood of an exchange and you need traders to generate volume, the CBOE has benefitted from the volume generated through the CBOT member's exercise rights. One could easily assume some percentage of this trading pool wouldn't have been exposed to the CBOE's products if not for this original agreement. The time for the CBOE to dispute this agreement should have been while the original charter was being established. The CBOE agreed to the exercise rights because they knew they needed and wanted the CBOT partnership. Thirty years later the CBOE has established themselves and can stand alone without the CBOT, is this a good enough reason to eliminate a prior agreement? Which brings me t o my s econd point, the CBOE (and the rest of the exchange sector) didn't realize the valuations of the exchanges until the CME went public and now they'd like to extiguish the exercise rights? Wouldn't we all like to change our decisions after we see what the future brings? As you know the CBOE is going ahead with their demutualization are they assuming a favorable ruling? I think this is called "counting your chickens before they hatch". The CBOE is poised to receive a generous market valuation upon their IPO please don't allow them to cut out the CBOT Full members to feed their greed.

John V. Grimes