From: Erskine S. Adam, Jr.
Sent: February 16, 2007
To: rule-comments@sec.gov
Subject: File No. SR-CBOE-2006-106


Nancy M. Morris
Secretary, Securities and Exchange Commission
100 F. Street, NE
Washington, DC 20549-1090

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

I have been a full member of the Chicago Board of Trade (CBOT) since 1968.

The CBOT financed, researched, envisioned and created the Chicago Board Options Exchange (CBOE). The CBOT financed all the research and startup costs involved to launch the CBOE. The first trades were made on the trading floor in the CBOT building.

As the creator of the CBOE all CBOT members were entitled to become members of CBOE. To disallow the full members of the CBOT to participate in the demutualization of the CBOE would be same as telling Bill Gates that he was no longer entitled to his Microsoft shares because the company was now public and owned by those shareholders.

Do not disenfranchise the members of the CBOT. We created the CBOE the same as Bill Gates created Microsoft. We are entitled to our share of the pie. The members of the CBOE have flourished because of the CBOT memberís vision to create their exchange. Do not let their greed leave us with nothing for our efforts and investment.

Sincerely,

Erskine S. Adam, Jr.
CBOT full member, 1968