From: Norm Friedman
Sent: February 16, 2007
To: rule-comments@sec.gov
Subject: File No. SR-CBOE-2006-106


To whom it may concern

I have been a member of the CBOT since 1984. I became a member of the CBOT as a result of me selling my CBOE membership, that I purchased as an original member in April 1973, and buying a CBOT membership.

My purpose for executing this membership exchange, was to give myself the flexibility of being able to trade at either exchange as my needs dictated. I traded at the CBOE as a CBOT member until 1996 when I decided to retire from active trading. I then leased my membership to CBOE traders. The CBOE continued to recognize me as a voting member.

I purchased my CBOT with the legal assumption that I would have the same "rights and privileges" as a CBOE member. These "rights and privileges" have been reaffirmed many times over the past 30 years starting with the original CBOE charter. These agreements have been signed by both exchanges.

The idea that the signed legal agreements confirming my status with the CBOE, as a member with the same "rights and privileges" is not valid because of a name change, is ridiculous.

The CBOE is obligated to stand by their "TRADE"!

Sincerely

Norm Friedman
CBOT Member