CBOECboe Global Markets

We note your presentation of adjusted combined income statement reconciliations for the twelve months ended December 31, 2017 and 2016 and the three months ended December 31, 2016. Please tell us how your presentation complies with Question 102.10 of the Non-GAAP Financial Measures Compliance and Disclosure Interpretations issued on October 17, 2017.

We respectfully acknowledge the Staff’s comment regarding the adjusted combined income statement reconciliation on page 15 of Exhibit 99.1. In response to the Staff’s comment, we will revise the adjusted combined income statement reconciliation section of our earnings release filed as Exhibit 99.1 (the “Exhibit”) to Form 8-K in future filings to exclude net revenue line items and other line items not impacted by non-GAAP adjustments.

Rest of the answer

We will also change the formatting of the schedule to make it evident that the Exhibit is not an income statement by moving the non-GAAP reconciliation line items below the combined results presentation.

We acknowledge our responsibility for the accuracy and adequacy of our disclosures. If you have any questions or would like to discuss this response, please contact the undersigned at 312-786-5600.

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We note from your response to our prior comment that you propose to revise your presentation of your adjusted combined income statement reconciliation in your earnings release, which will still include a presentation of your combined results as if the Bats acquisition occurred at the beginning of the period(s) presented.

Rest of the question

Please clarify if these combined results represent a pro forma presentation under Article 11 of Regulation S-X as we note your disclosure on page 14 states that results on a combined basis are non- GAAP. Include within your response your proposed presentation in a tabular format.

In response to the Staff’s comment, we advise that the combined results are presented on a non-GAAP basis and do not represent a pro forma presentation under Article 11 of Regulation S-X. We believe that the non-GAAP financial measures presented provide additional and comparative information to assess trends in our core operations and a means to evaluate period-to-period comparisons. These non-GAAP financial measures are provided as additional information to the investors.

Rest of the answer

Please see the proposed updated form of tabular format in the attached Exhibit A.

We acknowledge our responsibility for the accuracy and adequacy of our disclosures. If you have any questions or would like to discuss this response, please contact the undersigned at 312-786-5600.

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