Exhibit B

HEDGE
Street

(8) In each case above, “Y” equals the last Crude Oil Price rounded to
the nearest one dollar ($1.00) as reported by the Source Agency.

(iii) [except for renumeration, this Rule is unchanged]
(g) [unchanged]

(h) REPORTING LEVEL — The Reporting Level for the $100 Crude Oil
Binary Hedgelets shall be 350 1,750 Contracts.

(i) - (0) [unchanged]

RULE 12.60 — RULE 12.63 [unchanged]

RULE 12.64 FEDERAL FUNDS BINARY HEDGELET CONTRACTS
(a) - (e) [unchanged]

(f) PAYOUT CRITERION -— The Payout Criterion for each Contract will
be set by HedgeStreet at the time the Binary Contracts are initially issued. For the
Federal Funds Binary Hedgelet Contract, the Payout Criteria for the Contracts will
be set as follows:

(i) CYCLICAL FEDERAL FUNDS BINARY HEDGELET
CONTRACTS

(1) Binary Hedgelet Contract 1: One Contract will have a Payout
Criterion equal to X — 0.25%.

(2) — (5) [except for renumeration, these Rules are unchanged]
(ii) [unchanged]
(g) — (0) [unchanged]
RULE 12.65 [unchanged]
RULE 12.66 GOLD BINARY HEDGELET CONTRACTS
(a) - (f) [unchanged]

(g) MINIMUM TICK — The Minimum Tick size for Gold Binary Hedgelets
shall be $0.05 $0.50.

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


Exhibit B

HEDGE
Street

(h) REPORTING LEVEL - The Reporting Level for the Copper Binary
Hedgelets shall be 400 210 Contracts.

(i) POSITION LIMIT — The Position Limits for the Copper Binary
Hedgelet Contracts shall be 3,000 300 Contracts.

@ -O@

(m) SETTLEMENT VALUE - The Settlement Value is the amount paid to
the holder of the in the money Contract on the Settlement Date. The Settlement
Value of an in the money Copper Binary Contract is $40 $100.

(n) - (0) [unchanged]

RULE 12.78 — RULE 12.81 [unchanged]

RULE 12.82 HEATING OIL BINARY HEDGELET CONTRACTS
(a) - (e) [unchanged]

(f) PAYOUT CRITERION - The Payout Criterion for each Contract will
be set by HedgeStreet at the time the Binary Contracts are initially issued. For the
Heating Oil Binary Hedgelet Contracts, the Payout Criteria for the Contracts will be
set as follows:

(i) SPOF DAILY HEATING OIL BINARY HEDGELET
CONTRACTS

(1)—(12) [unchanged]

(ii) WEEKLY HEATING OIL BINARY HEDGELET
CONTRACTS

(1) Binary Hedgelet Contract 1: One Contract will have a Payout
Criterion of greater than Y (rounded to the nearest five cents ($0.05)) - $0.15.

(2) Binary Hedgelet Contract 2: One Contract will have a Payout
Criterion of greater than Y (rounded to the nearest five cents ($0.05)) - $0.10.

(3) Binary Hedgelet Contract 3: One Contract will have a Payout
Criterion of greater than Y (rounded to the nearest five cents ($0.05)) - $0.05.

(4) Binary Hedgelet Contract 4: One Contract will have a Payout
Criterion of greater than Y (rounded to the nearest five cents ($0.05)).

1825 S. Grant Street

Suite 500

‘San Mateo, CA 94402

Tel: 650.638.3500
www.hedgestreet.com Fax: 650.638.3501


Exhibit B

HEDGE
Street

(5) Binary Hedgelet Contract 5: One Contract will have a Payout
Criterion of greater than Y (rounded to the nearest fifty cents ($0.50)) + $0.50.

(6) Binary Hedgelet Contract 6: One Contract will have a Payout
Criterion of greater than Y (rounded to the nearest fifty cents ($0.50)) + $1.00.

(7) Binary Hedgelet Contract 7: One Contract will have a Payout
Criterion of greater than Y (rounded to the nearest fifty cents ($0.50)) + $1.50.

(8) In each case above, “Y” equals the last Expiration Value of
Natural Gas rounded to the nearest fifty cents ($0.50) as reported by the Source

Agency.

(iii) [except for renumeration, this Rule is unchanged]
(g) [unchanged]

(h) REPORTING LEVEL - The Reporting Level for the Natural Gas
Binary Hedgelets shall be 200 700 Contracts.

(i) - (0) [unchanged]

RULE 12.69 [unchanged]

RULE 12.70 SILVER BINARY HEDGELET CONTRACTS
(a) - (e) [unchanged]

(f) PAYOUT CRITERION - The Payout Criterion for each Contract will
be set by HedgeStreet at the time the Binary Contracts are initially issued. For the
Silver Binary Hedgelet Contract, the Payout Criteria for the Contracts will be set as
follows:

(i) SPOF DAILY SILVER BINARY HEDGELET
CONTRACTS

(1)-(12) | [unchanged]

(ii) WEEKLY SILVER BINARY HEDGELET

CONTRACTS

(1) Binary Hedgelet Contract 1: One Contract will have a Payout
Criterion of greater than Y (rounded to the nearest twenty-five cents (25)) - 75.

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


HEDGE
Street

Exhibit B

(h) REPORTING LEVEL - The Reporting Level for the $100 Gold Binary

Hedgelets shall be 447 1,750 contracts.

(i) POSITION LIMIT - The Position Limits for the $100 Gold Binary
Hedgelets shall be 25,000 2,500 Contracts.

G) - (1) [unchanged]

(m) SETTLEMENT VALUE - The Settlement Value is the amount paid to

the holder of the in the money Contract on Settlement Date. The Settlement Value

of an in the money Gold Binary Contract is $49 $100.
(n) - (0) [unchanged]
RULE 12.67 [unchanged]
RULE 12.68 NATURAL GAS BINARY HEDGELET CONTRACTS

(a) - (e) [unchanged]

(f) PAYOUT CRITERION -— The Payout Criterion for each Contract will
be set by HedgeStreet at the time the Binary Contracts are initially issued. For the

Natural Gas Binary Hedgelet Contract, the Payout Criteria for the Contracts will be

set as follows:

(i) SPOF DAILY NATURAL GAS BINARY HEDGELET

CONTRACTS
(1)-(12) [unchanged]

(ii) WEEKLY NATURAL GAS BINARY HEDGELET
CONTRACTS

(1) Binary Hedgelet Contract 1: One Contract will have a Payout
Criterion of greater than Y (rounded to the nearest fifty cents ($0.50) - $1.50.

(2) Binary Hedgelet Contract 2: One Contract will have a Payout
Criterion of greater than Y (rounded to the nearest fifty cents ($0.50)) - $1.00.

(3) Binary Hedgelet Contract 3:_One Contract will have a Payout
Criterion of greater than Y (rounded to the nearest fifty cents ($0.50)) - $0.50.

(4) Binary Hedgelet Contract 4: One Contract will have a Payout
Criterion of greater than Y (rounded to the nearest fifty cents ($0.50).

www.hedgestreet.com

1825 S. Grant Street
Suite 500

‘San Mateo, CA 94402
Tel: 650.638.3500
Fax: 650.638.3501


Exhibit B

EDGE
Street

(a) - (e) [unchanged]

(f) PAYOUT CRITERION -— The Payout Criterion for each Contract will
be set by HedgeStreet at the time the Binary Contracts are initially issued. For the
Copper Binary Hedgelet Contract, the Payout Criteria for the Contracts will be set
as follows:

(i) SROF DAILY COPPER BINARY HEDGELET
CONTRACTS

(1)-—(10) [unchanged]

(ii) WEEKLY COPPER BINARY HEDGELET

CONTRACTS

(1) Binary Hedgelet Contract 1: One Contract will have a Payout
Criterion of greater than Y (rounded to the nearest ten cents (10)) - 30.

(2) Binary Hedgelet Contract 2: One Contract will have a Payout
Criterion of greater than Y (rounded to the nearest ten cents (10)) - 20.

(3) Binary Hedgelet Contract 3: One Contract will have a Payout
Criterion of greater than Y (rounded to the nearest ten cents (10)) - 10.

(4) Binary Hedgelet Contract 4: One Contract will have a Payout
Criterion of greater than Y (rounded to the nearest ten cents (10)).

(5) Binary Hedgelet Contract 5: One Contract will have a Payout
Criterion of greater than Y (rounded to the nearest ten cents (10)) + 10.

(6) Binary Hedgelet Contract 6: One Contract will have a Payout
Criterion of greater than Y (rounded to the nearest ten cents (10)) + 20.

(7) Binary Hedgelet Contract 7: One Contract will have a Payout
Criterion of greater than Y (rounded to the nearest ten cents (10)) + 30.

(8) In each case above, “Y” equals the last Copper value rounded to
the nearest ten cents (10) as reported by the Source Agency.

(iii) [except for renumeration, this Rule is unchanged]

(g) MINIMUM TICK - The Minimum Tick size for the Copper Binary
Hedgelets shall be $0.05 $0.50.

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


HEDGE
Street

October 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: Rule Certification: Amends the Payout Criteria for the Binary Federal
Funds Contract; For Certain Other Binary Contracts, HedgeStreet® a) De-
lists Spot Contract Durations and offers Daily and Weekly Contract
Durations; b) Increases the Maximum Settlement Value to $100; and c)
Amends the Minimum Tick Size — Submission pursuant to Commission
Regulation §40.6(a)

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 certifies with
the Commission its intent to make the following changes effective on the dates specified
below;

Amendment to Payout Criteria of Federal Funds Binary Contracts

An amendment to the Payout Criteria for the existing Federal Funds Binary Contracts
currently offered under Cyclical duration and represented by Rule 12.65. HedgeStreet
intends to implement this rule amendment on Monday, October 16, 2006.

De-List Certain Spot Contracts and Add Daily/Weekly Contracts

The following Binary Spot Contracts will be de-listed; Silver, Copper, Crude Oil, Natural
Gas, Heating Oil, and Wholesale Gasoline contracts (“Spot Contracts”). The Spot
Contracts have a last trading date of Monday, October 16, 2006. Therefore, no open
interest in the Spot Contracts will be present at the close of business of Monday, October
16, 2006. HedgeStreet will list new Daily and Weekly Binary Contracts for Silver, Copper,
Crude Oil, Natural Gas, Heating Oil and Wholesale Gasoline. The Weekly Contracts will
be issued and available for trading on HedgeStreet on Monday, October 16, 2006. The
Daily Contracts will be issued and available for trading on HedgeStreet Tuesday, October
17, 2006.

Increase Maximum Settlement Value of Certain Binary Contracts
HedgeStreet is also increasing the maximum Settlement Value for all Binary Gold, Silver,

and Copper Contracts from $10 to $100. As a result of the increase in the maximum

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


Exhibit B

HEDGE
Street

(4) Binary Hedgelet Contract 4: One Contract will have a Payout
Criterion of greater than Y (rounded to the nearest five cents ($0.05)).

(5) Binary Hedgelet Contract 5: One Contract will have a Payout
Criterion of greater than Y (rounded to the nearest five cents ($0.05)) + $0.05.

(6) Binary Hedgelet Contract 6:_One Contract will have a Payout
Criterion of greater than Y (rounded to the nearest five cents ($0.05)) + $0.10.

(7) Binary Hedgelet Contract 7: One Contract will have a Payout
Criterion of greater than Y (rounded to the nearest five cents ($0.05)) + $0.15.

(8) In each case above, “Y” is measured in U.S. Dollars and equals
the last Wholesale Gasoline price or value rounded to the nearest five cents ($0.05)
as reported by the Source Agency.

(iii) [except for renumeration, this Rule is unchanged]
(g) [unchanged]

(h) REPORTING LEVEL - The Reporting Level for the Wholesale
Gasoline Binary Hedgelets shall be 459 140 Contracts.

(i) - (0) [unchanged]
RULE 12.85 ~ RULE 12.86 [unchanged]

[End Rulebook]

[the remainder of this page is intended to be blank]

1825 S. Grant Street
Suite 500
‘San Mateo, CA 94402,
Tel: 850.638.3500
www.hedgestreet.com Fax: 650.638.3501


Exhibit B

HEDGE
Street

(5) Binary Hedgelet Contract 5: One Contract will have a Payout
Criterion of greater than Y (rounded to the nearest five cents ($0.05)) + $0.05.

(6) Binary Hedgelet Contract 6: One Contract will have a Payout
Criterion of greater than Y (rounded to the nearest five cents ($0.05)) + $0.10.

(7) Binary Hedgelet Contract 7: One Contract will have a Payout
Criterion of greater than Y (rounded to the nearest five cents ($0.05)) + $0.15.

(8) In each case above, “Y” is measured in U.S. Dollars and equals
the last Heating Oil price rounded to the nearest five cents ($0.05), as reported by

the Source Agency.

(iii) [except for renumeration, this Rule is unchanged]
(g) — (0) [unchanged]
RULE 12.83 [unchanged]
RULE 12.84 WHOLESALE GASOLINE BINARY HEDGELET CONTRACTS
(a) - (e) [unchanged]

(f) PAYOUT CRITERION - The Payout Criterion for each Contract will
be set by HedgeStreet at the time the Binary Contracts are initially issued. For the
Wholesale Gasoline Binary Hedgelet Contract, the Payout Criteria for the Contracts
will be set as follows:

(i) SPOF DAILY WHOLESALE GASOLINE BINARY
HEDGELET CONTRACTS

(1)-(12) [unchanged]

(ii) WEEKLY WHOLESALE GASOLINE BINARY
HEDGELET CONTRACTS

(1) Binary Hedgelet Contract 1: One Contract will have a Payout
Criterion of greater than Y (rounded to the nearest five cents ($0.05)) - $0.15.

(2) Binary Hedgelet Contract 2: One Contract will have a Payout
Criterion of greater than Y (rounded to the nearest five cents ($0.05)) - $0.10.

(3) Binary Hedgelet Contract 3: One Contract will have a Payout
Criterion of greater than Y (rounded to the nearest five cents ($0.05)) - $0.05.

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


Exhibit B

HEDGE
Street

(2) Binary Hedgelet Contract 2: One Contract will have a Payout
Criterion of greater than Y (rounded to the nearest twenty-five cents (25)) - 50.

(3) Binary Hedgelet Contract 3: One Contract will have a Payout
Criterion of greater than Y (rounded to the nearest twenty-five cents (25)) - 25.

(4) Binary Hedgelet Contract 4: One Contract will have a Payout
Criterion of greater than Y (rounded to the nearest twenty-five cents (25)).

(5) Binary Hedgelet Contract 5: One Contract will have a Payout
Criterion of greater than Y (rounded to the nearest twenty-five cents (25)) + 25.

(6) Binary Hedgelet Contract 6: One Contract will have a Payout
Criterion of greater than Y (rounded to the nearest twenty-five cents (25)) + 50.

(7) Binary Hedgelet Contract 7: One Contract will have a Payout
Criterion of greater than Y (rounded to the nearest twenty-five cents (25)) + 75.

(8) In each case above, ““Y” equals the last Silver Price rounded to the
nearest twenty-five cents (25) as reported by the Source Agency.

(iii) [except for renumeration, this Rule is unchanged]

(g) MINIMUM TICK — The Minimum Tick size for Silver Binary
Hedgelets shall be $0-05 $0.50.

(h) REPORTING LEVEL ~ The Reporting Level for the Silver Binary
Hedgelet Contracts shall be 625 1,400 Contracts.

(i) POSITION LIMIT — The Position Limits for the Silver Binary Hedgelets
shall be 20,000 2,000 Contracts.

@ -@

(m) SETTLEMENT VALUE - The Settlement Value is the amount paid to
the holder of the in the money Contract on the Settlement Date. The Settlement
Value of an in the money Silver Binary Contract is $40 $100.

(n) — (0) [unchanged]
RULE 12.71 — RULE 12.76 [unchanged]

RULE 12.77 COPPER BINARY HEDGELET CONTRACTS

1825 S, Grant Street
Sulte 500
‘San Mateo, CA 94402
Tel: 850.638.3500
www.hedgestreet.com Fax: 650.638.3501


Exhibit B

HEDGE
Street

EXHIBIT B

Amendments to Rules 12.59, 12.64, 12.66, 12.68, 12.70, 12.77, 12.82, 12.84
(The following new Rule additions are underlined and deletions are stricken out)

RULE 12.59 CRUDE OIL BINARY HEDGELET CONTRACTS
(a) - (e) [unchanged]

(f) PAYOUT CRITERION — The Payout Criterion for each Contract will
be set by HedgeStreet at the time the Binary Contracts are initially issued. For the
Crude Oil Binary Hedgelet Contract, the Payout Criteria for the Contracts will be
set as follows:

(i) SPOF DAILY CRUDE OIL BINARY HEDGELET
CONTRACTS

(1)—(12) — [unchanged]

(ii) WEEKLY CRUDE OIL BINARY HEDGELET

CONTRACTS

(1) Binary Hedgelet Contract 1: One Contract will have a Payout
Criterion of greater than Y (rounded to the nearest $1.00) - $3.00.

(2) Binary Hedgelet Contract 2: One Contract will have a Payout
Criterion of greater than Y (rounded to the nearest $1.00) - $2.00.

(3) Binary Hedgelet Contract 3: One Contract will have a Payout
Criterion of greater than Y (rounded to the nearest $1.00) - $1.00.

(4) Binary Hedgelet Contract 4: One Contract will have a Payout
Criterion of greater than Y (rounded to the nearest $1.00).

(5) Binary Hedgelet Contract 5: One Contract will have a Payout
Criterion of greater than Y (rounded to the nearest $1.00) + $1.00.

(6) Binary Hedgelet Contract 6: One Contract will have a Payout
Criterion of greater than Y (rounded to the nearest $1.00) + $2.00.

(7) Binary Hedgelet Contract 7: One Contract will have a Payout
Criterion of greater than Y (rounded to the nearest $1.00) + $3.00.

1825 S. Grant Street

Suite 500

San Mateo, CA 94402

Tel: 650.638.3500
www.hedgestreet.com Fax: 650.638.3501


Exhibit A

“
HEDGE
Street
EXHIBIT A
Max NEW
HedgeStreet | (Binary)Asset/ . Effective | Settlement ae
Category . Action Minimum
Rule Duration Date Value Tick Siz
$10 or $100 | 1 "78
. | Payout Criteria
Interest Rates | 12.64 Federal Funds Addition Only 10/16/06 $100 | No change
+Max Settlement 10/17/06
Value and for Daily;
12.66 Gold + Min Tick Size 10/16/06 $100 $0.50
for
Commodities SPOT to DAILY TOs
. to
12.70 Silver Add WEEKLY 10/16/06 $100 $0.50
SPOT to DAILY 10/17/06
12.77 Copper Add WEEKLY 10/16/06 $100 $0.50
. SPOT to DAILY 10/17/06
12.59 Crude Oil Add WEEKLY 10/16/06 $100 | No change
SPOT to DAILY 10/17/06
Fuels 12.68 Natural Gas ‘Add WEEKLY 10/16/06 $100 | No change
. . SPOT to DAILY 10/17/06
12.82 Heating Oil Add WEEKLY 10/16/06 $100 | No change
SPOT to DAILY 10/17/06
12.84 Wholesale Gas ‘Add WEEKLY 10/16/06 $100 | No Change
1825 S. Grant Street
‘Suite 500

www.hedgestreet.com

San Mateo, CA 94402
Tel: 650.638.3500
Fax: 650.638.3501



HEDGE
Street

Settlement Value amount, HedgeStreet is amending the reporting levels and speculative
position limits for these Contracts in order to accommodate the larger maximum Settlement

Value. HedgeStreet intends to implement these rule amendments on Tuesday, October 17,
2006.

Change Minimum Tick in Certain Binary Contracts

In addition to increasing the Settlement Value of the Binary Gold, Silver and Copper
Contracts to $100, HedgeStreet certifies that the minimum tick size of all such Binary
Gold, Silver and Copper Contracts will go from $0.05 to $0.50 effective Tuesday, October
17, 2006. Since the current Contracts that have a Minimum Tick size of $.05 have a Last
Trade Date of Monday, October 16, 2006, there will be no open interest in such Contracts
upon the close of business on Monday, October 16, 2006.

The aforementioned amendments are summarized in Exhibit A. The applicable rule
amendments are defined in Exhibit B. Any rule deletions are stricken out while the
amendments and/or additions are underlined.

No substantive opposing views were expressed to HedgeStreet with respect to these
amendments.

Should you have any questions regarding the above, please do not hesitate to contact
Stephanie Ford by telephone at (650) 638-3511 or by email at sford@hedgestreet.com.

Sincerely,

Stephanie Ford
Vice President, Legal & Compliance

ce: Tom Leahy — CFTC
Phil Colling - CFTC
Clarissa Manansala — HedgeStreet, Inc.

1825 S. Grant Street
Sulte 500
San Mateo, CA 94402

Tel: 650.638.3500
www.hedgestreet.com Fax: 650.638.3501