December 20, 2019 John Pietrowicz Chief Financial Officer CME Group, Inc. 20 South Wacker Drive Chicago, IL 60606 Re: CME Group, Inc. Form 10-K for the Fiscal Year Ended December 31, 2018 Filed February 28, 2019 File No. 001-31553 Dear Mr. Pietrowicz: We have completed our review of your filings. We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. Sincerely, Division of Corporation Finance Office of Finance