From: Alan Matthew
Sent: February 18, 2007
To: rule-comments@sec.gov
Subject: File No. SR-CBOE-2006-106


RE: FILE No. SR-CBOE-2006-106

Nancy M. Morris
Secretary, Securities and Exchange Commission 100 F. Street, NE Washington, DC 20549-1090

Dear. Ms. Morris:

I am writing in regard to the CBOE-CBOT dispute over trading rights.

I started my career at the Chicago Board of Trade as a messenger clerk. I remember that the Board of Trade created the CBOE and that it was located in what now is referred as the Trade Checking Room adjacent to the trading floor. Over the years I worked my up to owning a Board of Trade membership. I have twice exercised my right to trade on the CBOE. I have also seen many traders lease a Board of Trade membership in order to trade on the CBOE.

Last week the CBOE exchange purchased a CBOE trading right on the bid offer forum currently in place at the Board of Trade. I do not understand how the CBOE can claim that the exercise right should be declared invalid. There is enormous precedent and history to prove that the Board of Trade and the CBOE are linked together by the Board of Trade exercise right.

Thank you.

Alan Matthew
Chicago Board of Trade Full Member