Subject: File No. SR-CBOE-2006-106
From: marshall spiegel
Affiliation: Retired equity member CBOE and CME

June 25, 2007

The "comments attached" are being partly filed in rebuttal to the June 15, 2007 filing by CBOE external "regulatory" counsel Michael L. Meyer of Schiff-Hardin that was just posted to this website. Also contained within this is a document that was just filed last week in the Delaware Chancery Court.

The last document to be filed in rebuttal is a September 1, 2001 letter published by former censured CBOE Chairman and current board member, Mark Duffy, who is a recipient of a $200,000 annual payment by CBOE according to their latest S-4. Mr. Duffy's letter not only refers to the legal proceeding that Mr. Meyer has filed as an exhibit to his June 15 filing, but also reflects the very admission the CBOT relies on in their current Delaware Legal proceeding depicting him as the creator of this legal morass.

(Attached File #1: cboe2006106-144a.pdf)
(Attached File #2: cboe2006106-144b.pdf)
(Attached File #3: cboe2006106-144c.pdf)