Ms. Elizabeth K. King
Associate Director
Division of Market Regulation
Securities and Exchange Commission
100 F Street, N.E.
Mail Stop Room 6628
Washington, D.C. 20549

Re: SR-CBOE-2006-106

Dear Ms. King:

I am writing to urge the Commission to reject the Proposed Rule Change relating to the CBOEs December 12, 2006 proposed interpretation of Article Fifth (b) of CBOEs Certificate of Incorporation.

Throughout the more than forty year relationship between the CBOT and the CBOE there has never been an instance where the public would be better served if the CBOT involvement were terminated.

To the contrary, the inception, incubation, nurturing and guidance to maturity had the active influence of the CBOT directors and CBOT members. If the CBOT is at fault it is that at inception of the CBOE idea it did not conceptualize the revolutionary changes in exchange capital formation and structure to the industry some forty years later. The founding directors rather focused on the providing of options markets with depth and liquidity for the risk transferring public and the liquidity providing professionals. The driving responsibility of the CBOT directors was a fiduciary responsibility to its members and not an exercise in the dividing of profits forty years later.

I urge your commission to reject summarily the CBOEs attempt to confuse the current exchange restructurings with a delinquency by the CBOT and consider the clear intent of the CBOT to actively promote the CBOE as an exchange worthy of the transactional integrity and public confidence it has achieved.

Respectfully submitted,

William R. Weldon
CBOT Member