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                            August 30, 2023

       Jill M. Griebenow
       Chief Financial Officer
       Cboe Global Markets, Inc.
       433 West Van Buren Street
       Chicago, Illinois 60607

                                                        Re: Cboe Global
Markets, Inc.
                                                            Form 10-K for
Fiscal Year Ended December 31, 2022
                                                            Response Dated
August 16, 2023
                                                            File No. 001-34774

       Dear Jill M. Griebenow:

              We have reviewed your August 16, 2023 response to our comment
letter and have the
       following comments. In some of our comments, we may ask you to provide
us with information
       so we may better understand your disclosure.

              Please respond to these comments within ten business days by
providing the requested
       information or advise us as soon as possible when you will respond. If
you do not believe our
       comments apply to your facts and circumstances, please tell us why in
your response.

             After reviewing your response to these comments, we may have
additional
       comments. Unless we note otherwise, our references to prior comments are
to comments in our
       August 3, 2023 letter.

       Response Dated August 16, 2023

       Management's Discussion and Analysis of Financial Condition and Results
of Operations, page 2

   1.                                                   Your response to prior
comment two appears to be conclusory in nature without providing
                                                        sufficient detail
regarding the indirect consequences of climate-related regulation or
                                                        business trends,
including the specific items noted in our comment, and your assessment
                                                        thereof. Please further
address the following:

                                                              More fully
describe the indirect consequences of climate change and tell us how you
                                                            concluded they were
not material. Provide support for your assessment in relation to
                                                            your principal
operations, including, without limitation, your operation of trading
                                                            markets and
platforms.
 Jill M. Griebenow
Cboe Global Markets, Inc.
August 30, 2023
Page 2
                Your response indicates you are in the early stages of your
commitment to net zero
              emissions by 2050 and have not incurred related costs deemed
material in 2022.
              Provide us with additional information regarding the steps you
have taken and expect
              to take in connection with this commitment. Include
quantification of the costs
              incurred during the periods covered by your Form 10-K and
expected to be incurred
              in future periods, and tell us how you assessed materiality.

                Tell us how you assessed the materiality of the potential
climate-related opportunities
              identified in your response for purposes of disclosure.
2.       We note your response to prior comment three. Please include the
quantification
         requested by our comment with respect to the weather-related damages
to your property or
         operations for each of the periods covered by your Form 10-K, rather
than limited to two
         events in 2022. Please also tell us how you considered disclosing the
risks that the
         physical effects of climate change may have on global operations, your
third-party data
         centers and cloud service providers, and customers, given the heavy
dependence on
         technology noted in your response and the risk factors cited therein.
        Please contact Madeleine Mateo at 202-551-3465 or Jennifer Angelini at
202-551-3047
with any questions.



FirstName LastNameJill M. Griebenow                            Sincerely,
Comapany NameCboe Global Markets, Inc.
                                                               Division of
Corporation Finance
August 30, 2023 Page 2                                         Office of
Finance
FirstName LastName