Subject: File No. SR-CBOE-2007-107
From: Paul L. Richards
Affiliation: Full Member, Chicago Board of Trade

October 10, 2007

October 8, 2007

Paul L. Richards

Office of the Secretariat
Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549-1090

Attn: Ms. Nancy M. Morris, Secretary

VIA: Electronic Mail ONLY:

Ladies and Gentlemen,


CBOE has now put forward rule SR-CBOE-2007-091 as a codification of their extortion of the Exerciser Members of the Chicago Board of Trade that originated in SR-CBOE-2006-106.

Once again, CBOEs latest offering is nothing more than another blatant attempt to confiscate the property of those of us who are owners of CBOT Full Memberships and have Exercised at the CBOE, without just compensation. We paid the same dues, the same fees and had the same vote as the other CBOE members that is, until CBOE began extorting Exercisers for $4700 per month, plus regular dues and technology fees.

None of the rules submitted by the CBOE: SR-CBOE-2007-107, SR-CBOE-2007-91, SR-CBOE-2007-77, nor SR-2006-106 - serve any identifiable public purpose whatsoever. Each is just another tactic explored by the CBOE to expropriate, without compensation, the property of part of its Membership, and to transfer such property not inadvertently to another part of its Membership, including members of its Board of Directors the very body now seeking adoption of these matters.

The SEC should deny each of the above submissions by the CBOE.

Respectfully submitted,

Paul L. Richards
CBOT Full Member since 1990
CBOE Exerciser and Equity Owner, 1995-2007