This week, @dragonfly filed a comment letter with the CFTC on compute derivatives. Compute is a swiftly growing expense for tech companies, yet the market for hedging its cost is still nascent. The challenge starts with defining what’s being traded. Not all GPU-hours are equal: hardware, performance, and availability can materially affect their value. Liquid derivatives markets need comparable units of compute and reliable price benchmarks. @HadickM @bryanmedelman @peteryshin and I advocate for technology-neutral standards, equal treatment of credible pricing sources, and support for perpetual futures to hedge ongoing compute costs. We applaud @CFTC for taking on these important questions and laying the groundwork for a liquid, competitive compute derivatives market.

Yesterday, Dragonfly filed a comment letter supporting the CFTC’s proposed framework for prediction market event contracts. We support the Commission’s case-by-case review framework, including its structured procedures and settlement-focused test for determining when a contract “involves” a particular activity. We also support the Commission’s proposed definition of “gaming” in § 40.11(b)(1), rather than the alternative structural formulation discussed in the proposal. In addition, we support a public-interest analysis that recognizes the full range of benefits prediction markets can provide, including information aggregation, hedging and pricing utility, responsible innovation, and fair competition. We appreciate the Commission’s thoughtful work and this opportunity to comment. Clear rules will protect market integrity while allowing responsible innovation in US prediction markets.