RECEIVED

HEDGE
Street

September 13, 2006
VIA EMAIL: secretary@cftc.gov

Ms. Eileen A. Donovan, Acting Secretary
Secretary of the Commission

Commodity Futures Trading Commission
3 Lafayette Centre

1155 21st Street, N.W.

Washington, D.C. 20581

RE: HedgeStreet, Inc. Offers New Member Trading Incentive Program

Dear Acting Secretary Donovan:

Pursuant to Section 5c(c)(1) of the Commodity Exchange Act, as amended (“Act”), and
§40.6(a) of the regulations promulgated by the Commodity Futures Trading Commission
(the Commission”) under the Act, HedgeStreet, Inc. (“HedgeStreet”) hereby submits to
the Commission its intent to initiate a New Member Trading Incentive Program (the
“Program”). The Program will extend one $25 gift certificate to any participant that opens
an account, funds the account for the first time with a minimum of $100 and enters at least
one (1) trade on the market before the end of the Program Period. The value of the gift
certificate will not exceed $25 in purchases redeemable only on Amazon.com, Inc. The
duration of the Program will commence on Friday, September 15, 2006 and will continue
through Tuesday, October 31, 2006 (the “Program Period”).

The purpose of this letter is to i) notify the Commission of HedgeStreet’s intention to
initiate the Program at the start of business on Friday, September 15, 2006; and ii) outline
the relevant terms and conditions of the Program.

The Program

As a fully electronic, non-intermediated, designated contract market and derivatives
clearing organization, HedgeStreet is primarily focused on the retail investor and
optimizing his/her trading experience as a HedgeStreet member. HedgeStreet recognizes
that by offering special promotions such as the Program regarding its products and services
it is providing an education to the general public about the unique instruments available for
trading on HedgeStreet.

The terms and conditions that will apply to the Program are as follows:

= All participants of the Program must comply with the existing restrictions and
requirements set forth under the HedgeStreet eligibility and application procedures
represented by Chapter 3 of the HedgeStreet Rulebook, including, but not limited

1825 S. Grant Street
Suite 500
San Mateo, CA 94402
Tel: 650.638.3500
www-hedgestreet.com Fax: 650.638.3501


HEDGE
Street

to, Chapter 3.1(a)(i) which specifically states that an individual must be “old
enough to enter into a legally enforceable contract”;

* This Program will not award gifts of cash value. Rewards for those members
participating in the Program will include a $25 gift certificate (“Gift Certificate”)
which will be redeemable only towards purchases made through Amazon.com,
Inc.;

= A Participant will become eligible to receive the Gift Certificate once the
participant (i) opens an account on HedgeStreet (ii) funds his/her account for the
first time, and (iii) executes at least one trade on HedgeStreet at any time during the
Program Period;

« A Participant that has already opened an account on HedgeStreet but has not yet
funded such account is eligible to participate in the Program;

= The Program will not affect the terms and conditions of the Fee Waiver Program
(“Waiver Program”). All terms and conditions of the Waiver Program originally
certified with the Commission on January 28, 2005 pursuant to Section Sc(c)(1) of
the Act, and §40.6(a) of the regulations promulgated by the Commission under the
Act continue to be in full force and effect. HedgeStreet subsequently extended the
Waiver Program and certified with the Commission such extension on March 22,
2005, June 29, 2005, September 26, 2005 and on January 5, 2006 at which time
HedgeStreet certified that the Waiver Program would be extended until the close of
business on December 31, 2006;

= Itis the responsibility of each participant to follow the rules of HedgeStreet and the
Program, and;

= The Program will expire at the close of business on Tuesday, October 31, 2006.

HedgeStreet hereby certifies that the Promotion complies with the Commodity Exchange
Act, as amended, and the Commissions regulations adopted thereunder.

Should you have any questions or require additional information, please do not hesitate to
contact the undersigned at (650) 638-3511 or stord@hedgestrect.com.

Sincerely,

Stephanie Ford
Vice President, Legal & Compliance

ce: Clarissa Manansala — HedgeStreet, Inc.

1825 S. Grant Street
Suite 500
‘San Mateo, CA 94402
Tel: 650.638.3500
www.hedgestreet.com Fax: 650.638.3501