CFE

Via Electronic Mail

August 2, 2005

tETARIAT

Ms. Jean A. Webb

Secretary

Commodity Futures Trading Commission
Three Lafayette Centre

1155 21st Street, N.W.

Washington, D.C. 20581

Re: CBOE Futures Exchange, LLC Rule Certification
Submission Number CFE-2005-23

Dear Ms. Webb:

Pursuant to Section Se(c)(1) of the Commodity Exchange Act, as amended ("Act"), and
§40.6(a) of the regulations promulgated by the Commodity Futures Trading Commission
("Commission") under the Act, CBOE Futures Exchange, LLC ("CFE" or "Exchange") hereby
submits this rule change ("Amendment") to adjust the position limits for the Mini-Russell 1000
Index and the Russell 1000 Index futures contracts traded on CFE. The purpose of the
Amendment is to establish an aggregate position limit for CFE's Mini-Russell 1000 Index and
Russell 1000 Index futures contracts at a level not exceeding the equivalent of 5,000 Russell 1000
Index futures contracts. For purposes of these revised position limits, one Mini-Russell 1000
Index futures contract would be deemed to be equivalent to one-fifth (0.20) of one Russell 1000
Index futures contract.

The Amendment will become effective on August 4, 2005.

CFE is not aware of any substantive opposing views to the Amendment. CFE hereby
certifies that the Amendment complies with the Act and the regulations thereunder.

The Amendment, marked to show additions in underlined text and deletions in
[bracketed] text, consists of the following:

kkk

Rule 1602. Russell 1000 Index Futures Contract Specifications

(@) Position Limits. [A person may not own or control more than 5,000 contracts net
long or net short.] A person may not own or control more than the number of contracts
net Jong or net short in Russell 1000 Index futures contracts and Mini-Russell 1000 Index
futures contracts that in the aggregate would exceed the equivalent of 5,000 Russell 1000
Index futures contracts. Under this rule, one Mini-Russell 1000 Index futures contract
shall be deemed to be equivalent to one-fifth (0.20) of one Russell 1000 Index futures
contract.

For the purposes of this rule, the positions of all accounts directly or indirectly owned or
controlled by a person or persons, and the positions of all accounts of a person or persons

400 South LaSalle Street Chicago, Illinois 60605-1023 ‘www.cboe.com/cfe


Ms. Jean A. Webb
Page 2 of 2

acting pursuant to an expressed or implied agreement or understanding shall be
cumulated.

The foregoing position limit shall not apply to bona fide hedge positions meeting the
requirements of Commission Regulation §1.3(z)(1) and the rules of the Exchange.

ke RRE

Rule 2002. = Mini-Russel] 1000 Index Futures Contract Specifications

@ Position Limits. [A person may not own or contro! more than 25,000 contracts
net —_ long or net short.] A person may not own or control more than the number of
contracts net long or net short in Russell 1000 Index futures contracts and Mini-Russell
1000 Index futures contracts that in the aggregate would exceed the equivalent of 5,000
Russell_]000 Index futures contracts. Under this rule, one Mini-Russell_1000 Index
futures contract shall be deemed to be equivalent to one-fifth (0.20) of one Russell 1000
Index futures contract.

For the purposes of this rule, the positions of all accounts directly or indirectly owned or
controlled by a person or persons, and the positions of all accounts of a person or persons
acting pursuant to an expressed or implied agreement or understanding shall be
cumulated.

The foregoing position limit shall not apply to bona fide hedge positions meeting the
requirements of Commission Regulation §1.3(z)(1) and the nules of the Exchange.

aK

Questions regarding this submission may be directed to David Doherty at (312) 786-

7466. Please reference our submission number CFE-2005-23 in any related correspondence.

cc:

CBOE Futures Exchange, LLC

miles = S\OPI—

Edward J. Joyce
President

Steven Benton (CFTC)
Mark Baumgardner (OCC)