From: Marc Brown
Sent: Fri 9/2/2005 3:18 PM
To: Rodriguez, Cyndi (Hoang Mai)
Cc: King, Elizabeth K.; Flynn, Deborah L.
Subject: 2 and 1/2 strikes

Dear Ms. Rodriguez,

Although we have never met I would like to "introduce" myself. My name is Marc Brown and I have been a trader at the CBOE for 18 years. I have also been a DPM these past 5 years. Many years ago I was instrumental, along with the assistance of Michael Schwartz (head strategist analyst with Oppenheimer and chairman of the Options Industry group at the time), with the implementation of the original 2 1/2 strike program. Needless to say, open interest in these particular strikes in these high volume products have been a tremendous strategic tool for all investors that trade them.

This recent proposal simply serves to allow these investors to create the same opportunities in the $50-75 range as they have enjoyed in the $25-50 range. I have been working closely with the CBOE as well as paying a visit to the SIA this past March. These additional 200 strikes per month on the current population of 200 stocks is a minuscule number compared to the 11,000 new strikes listed within the industry each month. Understanding that quote mitigation is a difficult issue, I would like you to note that this filing contains its own quote mitigation parameters that are surely reasonable in comparison.

For these reasons I respectfully request that you strongly consider approval of this filing and I would be happy to discuss it further and answer any questions you may have. I can be reached during trading hours at 312-460-1441.

I have met personally with Elizabeth King and spoken to Debbie Flynn as well regarding this matter. I am hoping to get their endorsement as well.


Marc Brown
Managing Partner