Subject: File No. SR-CBOE-2007-77
From: Paul L. Richards
Affiliation: Member, Chicago Board of Trade and Chicago Board Options Exchange

September 4, 2007

Paul L. Richards

31st August 2007

Chicago Board Options Exchange
400 South Lasalle Street
Chicago, IL 60605

Attn: Bill Brodsky, Chairman
and the CBOE Board of Directors

Re: CBOEs Interim Access Rule

Ladies and Gentlemen,

Please accept this letter of resignation under protest regarding the Exercise Right of my CBOT seat.

After over 12 years of Exercising my CBOT Membership here at the CBOE, paying all the dues and fees and voting as any other member, in addition to serving on CBOE Committees, through your new 'Interim Access Rule' you are confiscating my CBOE access without compensation. In fact, this rule is just a blatant attempt to try to extort $4700 per month, or $56,400 per year from me in order to maintain the CBOE access that I currently enjoy.

Purchasing my CBOT Full Membership gave me the belief that I not only shared in equity at the CBOT, but also at the CBOE, once I Exercised. Therefore, I now take my leave, under protest, with the fervent hope that the SEC and the Delaware Court find in my favor, so someday I can return after CBOEs interference with my rights is removed. Until then, economic damages from your unilaterally' denying trading access to this exchange where I have been contractually granted access will accrue.

Nothing regarding this forced resignation should in any way be interpreted as "surrender", voluntary or otherwise, of any of my rights, property or equity in the CBOE. In addition, I may have a claim against the CBOE and its Board of Directors that is superior to CBOT members who have not been CBOE members, and may choose to pursue legal action separate from the existing class action on this matter as well.

Respectfully submitted,

Paul Richards
CBOT Full Member since 1990
CBOE Exerciser Member and Equity Owner since 1995