HEDGE Tel EGS
Street

July 7, 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: HedgeStreet® Amends Payout Criteria for Nonfarm
Payroll Binary Hedgelet Contracts — Submission pursuant to Commission
Regulation §40.6(a)

Dear Secretary Donovan:

Pursuant to Section Sc(c)(1) of the Commodity Exchange Act, as amended (“Act”),
§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 that it intends to increase the maximum Settlement Value for the Nonfarm
Payroll Binary Hedgelet Contracts (“Contracts”), as represented by Rule 12.69, to $100.
As a result of the increase in the maximum Settlement Value amount, HedgeStreet is
amending i) the Payout Criteria for the Contracts; and ii) the reporting level for these
Contracts in order to accommodate the larger maximum Settlement Value. All
amendments for these Contracts are defined in Exhibit A. The rule deletions are stricken
out and the amendments and/or additions are underlined.

HedgeStreet intends to implement these rule amendments on Monday, July 10, 2006.

No substantive opposing views were expressed to HedgeStreet with respect to these
additions. HedgeStreet hereby certifies that these amendments comply with the Commodity
Exchange Act, as amended, and the Commissions regulations adopted thereunder.

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

cc: Clarissa Manansala — HedgeStreet , Inc.

1625 S. Grant Street
Sulte 500
San Mateo, CA 94402

Tel: 650.638.3500
www-hedgestreet.com Fax: 650.638.3501


Exhibit A

HEDGE
Street
EXHIBIT A

Amendments to Rule 12.69 only
(The following new Rule additions are underlined and deletions are stricken out)

RULE 12.69 NONFARM PAYROLLS BINARY HEDGELET CONTRACTS
(a) - (e) [unchanged]

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

(i) CYCLICAL NONFARM PAYROLLS BINARY
HEDGELET CONTRACTS

(1) Binary Hedgelet Contract 1: One Contract will have a Payout
Criterion of greater than 50,000 10,000.

(2) Binary Hedgelet Contract 2: One Contract will have a Payout
Criterion of greater than 70,008 30,000.

(3) Binary Hedgelet Contract 3: One Contract will have a Payout
Criterion of greater than 99,000 50,000.

(4) Binary Hedgelet Contract 4: One Contract will have a Payout
Criterion of greater than 0,000 70,000.

(5) Binary Hedgelet Contract 5: One Contract will have a Payout
Criterion of greater than 430,000 90,000.

(6) Binary Hedgelet Contract 6: One Contract will have a Payout
Criterion of greater than 458,000 110,000.

(7) Binary Hedgelet Contract 7: One Contract will have a Payout
Criterion of greater than 470,000 130,000.

(8) Binary Hedgelet Contract 8: One Contract will have a Payout
Criterion of greater than +99,060 150,000.

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


Exhibit A

HEDGE
Street

(9) Binary Hedgelet Contract 9: One Contract will have a Payout
Criterion of greater than 240,000 170,000.

(10) Binary Hedgelet Contract 10: One Contract will have a Payout
Criterion of greater than 230,000 190,000.

(11) Binary Hedgelet Contract 11: One Contract will have a Payout
Criterion of greater than 250,060 210,000.

(12) Binary Hedgelet Contract 12: One Contract will have a Payout
Criterion of greater than 270,000 230,000.

(13) Binary Hedgelet Contract 13: One Contract will have a Payout
Criterion of greater than 299,000 250,000.

(ii) [unchanged]
(g) [unchanged]

(h) REPORTING LEVEL — The Reporting Level for the Nonfarm Payroll
Binary Hedgelets shall be 425,000 12,500 contracts.

(i) - (0) [unchanged]

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

1825 S. Grant Street

Suite 500

‘San Mateo, CA 94402

Tel: 650.638.3500
www.hedgestreet.com Fax: 650.638.3501