June 11, 2010
Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Re: | CBOE Holdings, Inc. |
| Filed on Form S-1 |
| Registration No. 333-165393 |
Ladies and Gentlemen:
In connection with the above-captioned Registration Statement, we wish to advise that between May 27, 2010 and the date hereof 19,545 copies of the Preliminary Prospectus, dated May 27, 2010, were distributed as follows: 17,870 to 18 prospective underwriters; 1,587 to 1,587 institutional investors; 86 to 2 prospective dealers; 2 to 2 individuals; 0 to 0 rating agencies and 0 to 0 others.
We have been informed by the participating underwriters that they will comply with the requirements of Rule 15c2-8 under the Securities Exchange Act of 1934.
We hereby join in the request of the registrant that the effectiveness of the above-captioned Registration Statement, as amended, be accelerated to 12:00 p.m. on June 14, 2010 or as soon thereafter as practicable.
Very truly yours,
GOLDMAN, SACHS & CO.
As Representative of the
Prospective Underwriters
By: | /s/ Goldman, Sachs & Co. |
|
| (Goldman, Sachs & Co.) |
|