From: Stuart Reif
Sent: February 16, 2007
Subject: File No. SR-CBOE-2006-106

Securities and Exchange Commission 100 F Street, N.E. Washington, D.C. 20549-1090

Attn: Nancy M. Morris, Secretary

Re: File No. SR-CBOE-2006-106

Dear Ladies and Gentlemen,

The stated mission of the Securities and Exchange Commission is; “to protect investors, maintain fair, orderly, and efficient markets, and facilitate capital formation“. The proposed rule change requested by the CBOE is all about property rights and therefore seems outside the scope of the stated regulatory missions of the SEC. Upon the creation of the CBOE by the CBOT, certain privileges and property rights were contractually granted to CBOT members. The rule change requested by the CBOE is nothing more than an “end run” attempt to negate those property rights, having nothing to do with orderly, fair, and efficient markets. Property rights are legal issues. If negotiations of the parties fail, they should be decided by our court system. The American legal system is rightfully credited to be the cornerstone of the success of our country. I trust that the SEC will not fall victi m to the strategy of the CBOE in their attempt to circumvent the legal system of U.S.A. by rightfully denying their request for the subject rule change.

Respectfully Submitted,

Stuart Reif

Full Member, CBOT