Subject: File No. SR-CBOE-2006-106
From: Paul L. richards
Affiliation: Member, Chicago Board of Trade and Chicago Board Options Exchange

August 29, 2007

Paul L. Richards

20th August 2007

Office of the Secretariat
Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549-1090

Attn: Ms. Nancy M. Morris, Secretary

VIA: Electronic Mail ONLY:

Ladies and Gentlemen,


CBOE has now put forward rule SR-CBOE-2007-091 as a codification of their extortion of the Exerciser Members of the Chicago Board of Trade originated in SR-CBOE-2007-077, the Interim Access Rule.

In my opinion, the Interim Access Rule is nothing more than another blatant attempt by the CBOE to confiscate the property of those of us who are owners of CBOT Full Memberships and who also have Exercised at the CBOE, without just compensation. We have paid the same dues, the same fees and had the same vote as the other CBOE members. Now CBOE intends to offer us to keep our membership at the CBOE intact by extorting us for $4700 per month, in addition to the regular dues and technology fees already being assessed.

- 2 - August 20th, 2007

When reading through the CBOE propaganda one would be left believing that the CBOE has been magnanimous in handing out these temporary permits to us. In fact, they mention that the Exchange is making this change in the interest of fairness . If CBOEs definition of fairness is extortion to the degree of $56,400 per annum, then we have a different definition of fairness, indeed.

None of the rules submitted by the CBOE: SR-CBOE-2007-91, SR-CBOE-2007-77, nor SR-2006-106 - serve any identifiable public purpose whatsoever. Each is just another tactic explored by the CBOE to expropriate, without compensation, the property of part of its Membership, and to transfer such property not inadvertently to another part of its Membership, including members of its Board of Directors the very body now seeking adoption of these matters.

This entire matter is, of course, simply a property dispute. And, as such, is the subject of litigation in Delaware Chancery Court. Please deny CBOE these extortionist rule changes.

Respectfully submitted,

Paul L. Richards
CBOT Full Member since 1990
CBOE Exerciser and Equity Owner since 1995