FILE NO.: SR-CBOE-2006-106

February 21 2007

Ronald G Lindenberg

Securities and Exchange Commission
100 F Street NE
Washington D.C. 20549-1090

Attn: Nancy M Morris, Secretary

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

I started out on the floor of the CBOE as a runner for Becker in 1976. At that time the CBOE was on the 5th floor of the CBOT building. I became a member of the CBOE in 1978. I rented my first seat, and worked with Marty Goldstien. Then I went to work with O'Connor and Associates. I was working with Ralph Levy in 1982 when i bought a CBOE seat, i went totally on my own in 1984 after buying out my partner. I traded on that CBOE seat for four more years until 1986 when i sold the CBOE seat and bought the CBOT seat, the BIG seat around chicago as apposed to the little seat at the CBOE. I had to pay taxes on the capitol gains of the CBOE seat and then buy a CBOT seat although i never traded any differently doing all my business on the CBOE. I traded on the CBOE floor for another 2 and 1/2 years as a CBOT full seat owner. There were lots of other guys and gals doing the same thing trading up to a larger piece of the business. The CBOT seat was the over all seat and the CBOE seat as well as the ITEM seat, the Com seat, the GIM seat, and the ASSOCIATE seats were all just partial seats of the BOARD of TRADE. The Yellow badge the CBOT full seat said you could trade any of the products and that's what we did... many of the members of the CBOT were in those pits trading with the smaller CBOE seats... in the pits, building up the business of options trading. I then went and leased out my CBOT seat to a trader who passed the CBOT requirements but used the seat also exclusively for trading on the CBOE. I rented to that company for 12 or 13 years and all of which time they built up the CBOE business of the CBOT and CBOE membership. I still rent out that CBOT seat, though now to someone who is trading on the CBOT. I bought another of the lesser seats and traded using the COM seat the Commodity Options seat. I think that my point is that i can't see how the CBOE seat holders have a stand in there contention that I as a full seat holder of the CBOT am not entitled to the rights, obligations and rewards of that business i helped create and understood as did every one there... that as an owner, just as when the CBOT went public the COM seats and the IDEM seats and the ASSOCIATE seats and the GIM seats understood that they owned something and... but... that those who owned a Full CBOT seat was a partial owner of ALL the different contracts and business traded. In fact because of agreements between the different clearing firms, my acronym under which i traded for 12? years in CBOE type products and having moved over to the CBOT products... no one at the CBOE is allowed to use that acronym of REX unless i give it up at the CBOT. Its just another example of my ownership rights at the CBOE.