From: Lawrence C. Dorf
Sent: February 9, 2007
Subject: File No. SR-CBOE-2006-106

My name is Lawrence C. Dorf and I am a Full Member at the Chicago Board of Trade (CBOT). I am writing to submit my opinion on the Chicago Board Options Exchange (CBOE) plan to try and disallow the members of the CBOT their fair share in any distribution that the CBOE may have planned now or in the future. With the demutualization of exchanges all over the world and the great opportunity that it represents not only to the members of these exchanges but to the investor as well, it is obvious to me that the CBOE is trying to keep a larger share for themselves then what they are entitled too. The CBOE has signed many agreements with the CBOT over this issue and it is very clear that as long as the CBOT member has all three (3) parts of their membership, the CBOT Full Membership, the 27,338 shares of BOT stock and the ERP trading right, then the CBOT member is entitled to share as an equal in any and all distributions that the CBOE may try to do. The CBOE itself has given credence to the argument by itself trying on the open market to buy as many ERP memberships as they could at the price of $100,000.00 and have been in the market and bought ERP membership on other occasions. If these had no value then why would they attempt to extinguish these rights? It is very clear to see that what they want to do is keep the riches to themselves and the 900 or so CBOE members rather the rightfully share these with the approximately 1000 CBOT members who have in good faith kept their membership package together as a whole to share in any distribution by the CBOE. Also the argument that our right to exercise a CBOT membership at the CBOE is no longer valid because of the proposed merger between the CBOE and the Chicago Mercantile Exchange(CME) is also a smoke screen to try and eliminate the CBOT members right once again to share in any and all opportunities that may arise from the CBOE. It is a straight forward plan of bad business and greed. I do not believe that the SEC would allow this to happen under their authority.

Respectfully submitted by,

Lawrence C. Dorf
Member CBOT