Subject: File No. SR-CBOE-2005-39
From: Marc A. Brown
Affiliation: DPM-CBOE

November 16, 2005

Dear SEC,

This proposed rule filing is outstanding for the investor.

One need only check the open interest in these 200 active stocks to confirm that 2 1/2 strikes are an integral part of the Options Industry. Adding new strikes will only enhance the strategies available for all market participants. It is much better to have strikes listed that one knows will trade than to continue to list strikes that move all day with little or no activity. Thank You

Marc Brown