Subject: File No. SR-CHX-2016-20
From: Anonymous A.

November 12, 2017

The most recent comment letter and proposed transaction submitted by the Chicago Stock Exchange reads in circles. Who exactly is going to own this thing when the deal is done? It seems fairly hard to tell. One thing is however quite plain, none of the supposed U.S. based investors are really buying stock in the exchange. Instead, the U.S. investors are entering into something of a double option where they will either voluntarily, or involuntarily at Casins behest, flip the exchange to a buyer chosen by Casin.

If Casin identifies a buyer, who could be anyone from a Chinese government agency, to a non-descript affiliated company, it could cause the shares of the exchange to be flipped in no time flat. Theres a kicker too, the U.S. investors purchase is made, as seen on TV, at no risk to them because Casin has promised to cover any loss the U.S. investors have when selling the stock . . .that they just purchased.

Casin essentially has agreed to pay the U.S. "investors" to buy the Chicago exchange's stock, even where Casin can compel the sale of that stock to a third party of its choice. Not a bad deal, but a bit unusual: buy some stock any losses I suffer will be covered by the buyer. All the while the same opaque buyer in china can force me to immediately resell the stock I just purchased to anyone it chooses. Sound normal? I should hope not.

In the end, it looks like Casin is really trying to call all of the shots on who controls the stock exchange while even the U.S. investors are apparently willing to resell the Chicago Stock Exchange to whoever Casin chooses anyway.

This is not a safe deal for investors, and given Chinas often surreptitious methods of acquiring sensitive U.S. technology and information, a decidedly reckless transaction vis--vis our public interest.