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SEC Comment Letter for CME GROUP INC. (CME) (CIK 0001156375) (CME) — Jul 8, 2011

CME GROUP INC. (CME) (CIK 0001156375)
Date: July 8, 2011 · CIK: 0001156375 · Accession: 0000000000-11-041422

Regulatory Compliance Financial Reporting Internal Controls

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Reasoning

File numbers found in text: 001-31553

Date
July 8, 2011
Author
Branch Chief
Form
UPLOAD
Company
CME GROUP INC. (CME) (CIK 0001156375)

Letter

July 8, 2011 VIA E-Mail Mr. James E. Parisi Chief Financial Officer CME Group, Inc. 20 South Wacker Drive Chicago, Illinois 60606 Re: CME Group, Inc. Form 10-K for the year ended December 31, 2010 Filed February 28, 2011 Form 10-Q for the quarter ended March 31, 2011 Filed May 10, 2011 File No. 001-31553

Dear Mr. James E. Parisi: We have completed our review of your f iling. We remind you that our comments or changes to disclosure in res ponse to our comments do not for eclose the Commission from taking any action with respect to the company or th e filing and the company may not assert staff comments as a defense in any proceeding ini tiated by the Commission or any person under the federal securities laws of the United States. We urge all pers ons who are responsible for the accuracy and adequacy of the disclosure in the fi ling to be certain that the filing includes the information the Securities Exchange Act of 1934 and all applicable rules require.

Sincerely,
/s/ Daniel L. Gordon Daniel L. Gordon
Branch Chief

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July 8, 2011  VIA E-Mail

Mr. James E. Parisi Chief Financial Officer CME Group, Inc. 20 South Wacker Drive Chicago, Illinois 60606
Re: CME Group, Inc.
Form 10-K for the year ended December 31, 2010 Filed February 28, 2011 Form 10-Q for the quarter ended March 31, 2011 Filed May 10, 2011 File No. 001-31553

Dear Mr. James E. Parisi:
We have completed our review of your f iling.  We remind you that our comments or
changes to disclosure in res ponse to our comments do not for eclose the Commission from taking
any action with respect to the company or th e filing and the company may not assert staff
comments as a defense in any proceeding ini tiated by the Commission or any person under the
federal securities laws of the United States.  We urge all pers ons who are responsible for the
accuracy and adequacy of the disclosure in the fi ling to be certain that the filing includes the
information the Securities Exchange Act of 1934 and all applicable rules require.

Sincerely,
  /s/ Daniel L. Gordon   Daniel L. Gordon
Branch Chief