Subject: File No. S7-19-07
From: Robert Almy

August 20, 2008

First, the comments of Edward J. Joyce, President and Chief Operating Officer, CBOE have not been submitted within the time limits of the comment period and should be ignored.

Further, The Office of Economic Analysis (part of SEC) issued a memorandum June 9, 2008,


Which states in pertinent part:

"In summary, the results indicate that fails to deliver in non-optionable securities declined significantly after the elimination of the grandfather exception while fails to deliver in optionable securities increased significantly."

Both of these facts (SEC findings and conclusions) contradict the meritless claims of Mr. Joyce.