Subject: File No. SR-CBOE-2007-107
From: John C. Simms

November 17, 2007

U.S. Securities and Exchange Commissioners

Dear Commissioners,

The CBOE's request for a rule change is an attempt to extinguish property rights that have been granted contractually to CBOT members. This is an effort by the CBOE to deny their contractual obligations to the CBOT. This matter is about property rights and privileges and should be handled by our court system. Please deny their attempt for a rule change, and let our court system handle the matter.

Respectfully submitted

John C. Simms
CBOT full member
CBOT associate member