Subject: File No. SR-NASDAQ-2006-040
From: Jonathan E. Drayna
Affiliation: Vice President, Investor Relations, Associated Banc-Corp

December 12, 2006

To whom it may concern:

NASDAQ has discussed with us its proposed packaging of services related to our company's listing on the NASDAQ stock market, and the fees associated with this package of services.

We believe the new services offered in conjunction with our NASDAQ listing have meaningful value, and we intend to take advantage of these services in the future where possible.

Additionally, NASDAQ's proposed method of packaging services may increase competition among the providers of these services, which would ultimately benefit listed companies and our shareholders.