From: Gordon Gladstone
Sent: February 9, 2007
Subject: File No. SR-CBOE-2006-106

Dear Sirs,

I find it incredulous that you would consider making a legal ruling with regards to the filed documents that exist between the CBOT and the CBOE. As a full member of the CBOT I have leased my membership trading rights out through First options on the CBOE for many years. They have signed multiple legally binding documents with the CBOT acknowledging the existence of the trading right and still allow many CBOT full memberships to be leased currently to trade on the CBOE. This acknowledgement of these rights shows they still have current value and have assisted in creating liquidity for the stock options markets. It is beyond me that the CBOE allows the trading rights and then feels there is no value to them- with or without the accompanying stock. They have purchased exercise rights in the past two years and even as recently as two weeks ago. The excuse they forgot they had a bid in isn’t valid since if something doesn’t have any value in your eyes, you certainly wouldn’t be stupid enough to want to buy it!!!!!! In addition, this is a legal matter that belongs in the courts of Delaware since that is where the law suit began. I am sure if the CBOE wanted to make a fair offer for these rights and put it to a vote for the majority to rule the CBOT members would be willing to vote on this.

Gordon gladstone