SecProbe.io

May 9 , 2013

Via E -mail
Mr. James E. Parisi
Chief Financial Officer  & Senior Managing Director
Finance and  Corporate  Development
CME  Group Inc.
20 South Wacker Drive
Chicago , IL 60606

Re: CME Group  Inc.
 Form 10 -K for the Year Ended December 31 , 2012
 Filed March 1, 2013
File No. 001-31553

Dear Mr. Parisi :

We have reviewed your filing an d 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 this letter within ten business days by amending your filing, by
providing the requested information, or by advising us when you will provide the requested
response.   If you do not  believe our comments apply to your facts and circumstances or do not
believe an amendment is appropriate, please tell us why in your response.

After reviewing any amendment to your filing and the information you provide in
response to these  comments, w e may have  additional comments.

Form 10 -K for the Year Ended December 31 , 2012

Item 7. Management’s Discussion and Analysis of Financial Condition…, page 35

Revenues, page 37

1. Please tell us how you account for the incentive programs that you use to promote trading
and describe for us and tell us how you account for the broker rebates disclosed on page
39, citing the authoritative literature upon which you relied.

Liquidity and Capital Resources, page 50

2. In future filings, please revise your tabu lar presentation of contractual obligations to
include all of the obligations that fall within the specified categories  of Item 303(a)(5)(i)

Mr. James E. Parisi
CME  Group Inc.
May 9 , 2013
Page 2

 of Regulation S -K, including long -term debt obligations.  Your disclosure should also
include your interest commitments under your interest -bearing debt in this table, or
provide textual discussion of this obligation below the table.  If you provide a textual
discussion, the discussion should quantify the interest payments using the same time
frames stipulated i n the table .

Note 2. Summary of Significant Accounting Policies, page 66

Goodwill and Other Intangible Assets, page 67

3. In future filings, please revise to disclose your accounting policies related to intangible
assets subject to amortization.

Segment Reporting, page 69

4. Please tell us how you determined that you had one reportable segment and that CME,
CBOT, NYMEX, COMEX and KCBT are one operating segment.

Note 14. Contingencies, page 84

5. In future filings, please revise to disclose the amount of reas onably possible losses or
range of losses in excess of amounts accrued for all legal proceedings and other
contingencies or, where applicable, to state that such an estimate of the possible loss or
range of loss cannot be made.  We note that you provide su ch disclosure for the lawsuits
related to  MF Global only.  You may provide your disclosures on an aggregated basis.
Refer to ASC 450 -20-50.  Please provide us with your proposed disclosure.

Form 8 -K Filed February 5, 2013

Exhibit 99.1

6. Please note that  it is generally not appropriate to present a full non -GAAP income
statement for purposes of reconciling non -GAAP measures to the most directly
comparable GAAP measures .  Refer to Question 102.10 of the Compliance & Disclosure
Interpretation on Non -GAAP Fina ncial Measures.

We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules require.   Since the company and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.

 In responding to our comments, please provide  a written stat ement from the company
acknowledging that:

Mr. James E. Parisi
CME  Group Inc.
May 9 , 2013
Page 3

 the company is responsible for the adequacy and accuracy of the disclosure in the filing;

 staff comments or changes to disclosure in response to staff comments do not foreclose
the Commission from taking any action with respect to the filing; and

 the company may not assert staff comments as a defense in any proceeding initiated by
the Commission or any person under the federal securities laws of the United States.

If you have any questions, you may contact E ric McPhee at (202) 551 -3693 or me at
(202) 551 -3694.

Sincerely,

 /s/ Jonathan Wiggins

Jonathan Wiggins
Staff Accountant