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.