From: Stephen Cournoyer
Sent: February 24, 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,

My name is Steve Cournoyer and I have been a member of the CBOT for over 34 years. I would like to submit my opposition to the CBOE's proposed rule change SR-CBOE-2006-106.

My initial opposition to this rule change is that the there are underlying agreements that have existed between the CBOT and CBOE since the CBOT created the CBOE. This rule change presumes a contract no longer exists. This contract issue must necessarily be addressed before either side can precede in their own independent way. It would be preferable to have the contract dispute decided in the Delaware court where it now awaits a ruling.


Stephen Cournoyer