HEDGE
Street.

(i) WEEKLY VARIABLE GBP/USD CONTRACT

(1) CAP - The Cap shall be X + 0.05

(2) FLOOR - The Floor shall be X - 0.05

(3) DOLLAR MULTIPLIER - The Dollar Multiplier shall be 500.

(4) In each case, “X”* equals the last GBP/USD price, rounded to the
nearest 0.01, as reported in the GBP/USD foreign currency market at SPM ET on the
previous business day before the Weekly Variable GBP/USD Contract is listed for trading

on HedgeStreet.

) (ii) [except for renumbering, this rule is unchanged]
i) (iii) [except for renumbering, these rules are unchanged]
(g) - (0) [unchanged]

RULE 12.32 CURRENCY EXCHANGE USD/YEN VARIABLE PAYOUT
CONTRACTS

(a) - (c) [unchanged]
(f) PAYOUT CRITERION - The Payout Criterion for each Contract will be set by
HedgeStreet at the time the Variable Payout Contracts are initially issued. For the Variable

Payout Hedgelet Contract, the Payout Criteria for the Contracts will be set as follows;

(i) WEEKLY VARIABLE USD/YEN CONTRACT

1) CAP - The Cap shall be X + 5
(2) FLOOR - The Floor shall be X - 5

(3) DOLLAR MULTIPLIER - The Dollar Multiplier shall be 5.

(4) In each case, “X” equals the last USD/YEN price rounded to the nearest
1, as reported in the USD/YEN foreign currency market at 5PM ET on the previous
business day before the Weekly Variable USD/YEN Contract is listed for trading on

HedgeStreet.

@ (ii) [except for renumbering, this rule is unchanged]

i) (iii) [except for renumbering, these rules are unchanged]

1825 S. Grant Street

‘Suite 500

San Mateo, CA 94402

Tel: 650.638.3500
www.hedgestreet.com Fax: 650.638.3501


HEDGE
Street.

(4) In each case, “X” equals the last reported level Expiration Value of
Natural Gas, rounded to the nearest fifty cents ($.50), as reported by the Source Agency.

4 (ii) [except for renumbering, this rule is unchanged.]
4) (iii) [except for renumbering, this rule is unchanged.]
(g) - (0) [unchanged]
RULE 12.52 —- RULE 12.66 [unchanged]

RULE 12.67 MORTGAGE RATE (30 YEAR FRMS) 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 30-Year FRM
Binary Hedgelet Contract, the Payout Criteria for the Contracts will be set as follows;

(i) WEEKLY 30-YEAR FRMS BINARY HEDGELET

CONTRACT

(1) Binary Hedgelet Contract 1: One Contract will have a Payout Criterion
of greater than Y - 0.06%.

(2) Binary Hedgelet Contract 2: One Contract will have a Payout Criterion
of greater than Y - 0.03%.

(3) Binary Hedgelet Contract 3: One Contract will have a Payout Criteria
of greater than Y.

(4) Binary Hedgelet Contract 4: One Contract will have a Payout Criterion
greater than Y + 0.03%.

(5) Binary Hedgelet Contract 5: One Contract will have a Payout Criterion
greater than Y + 0.06%.

(6) In each case, “Y” equals the last 30-Year FRM regularly scheduled
release reported by the Source Agency.

9 (ii) [except for renumbering, this rule is unchanged.)

49 (iii) [except for renumbering, this rule is unchanged.]

1825 S. Grant Street

Suite 500

San Mateo, CA 94402

Tel: 650.638.3500
www.hedgestreet.com Fax: 650.638.3501


HEDGE
Street.

(3) DOLLAR MULTIPLIER - The Dollar Multiplier shall be 100.

(4) In each case, “X” equals the last Gasoline price, rounded to the nearest
five cents ($0.05), as reported by the Source Agency.

9 (ii) [except for renumbering, this rule is unchanged]
4 (iii) [except for renumbering, this rule is unchanged]
i¥ (iv) [except for renumbering, this rule is unchanged.]
9 (v) [except for renumbering, this rule is unchanged.
(g) - (0) [unchanged]
RULE 12.35 GOLD VARIABLE PAYOUT CONTRACTS
(a) - (e) [unchanged]
(f) PAYOUT CRITERION - The Payout Criterion for each Contract will be set by
HedgeStreet at the time the Variable Payout Contracts are initially issued. For the Variable

Payout Hedgelet Contract, the Payout Criteria for the Contracts will be set as follows;

(i) WEEKLY VARIABLE GOLD CONTRACT

(1) CAP - The Cap shall be X + $25

(2) FLOOR - The Floor shall be X - $25

(3) DOLLAR MULTIPLIER - The Dollar Multiplier shall be 1.

(4) In each case, “X” equals the last Expiration Value for Gold, rounded to
the nearest five dollars ($5.00), as reported by the Source Agency.

¥ (ii) [except for renumbering, this rule is unchanged]

4 (iii) [except for renumbering, these rules are unchanged]

(g) - (0) [unchanged]
RULE 12.36 CRUDE OIL VARIABLE PAYOUT CONTRACTS

(a) - (e) [unchanged]

1825 S. Grant Street
Suite 500

‘San Mateo, CA 94402
Tet 650.638.3500

www. hedgestreet.com Fax: 650.638.3501


HEDGE
Street.

(g) - (0) [unchanged]

RULE 12.33 CURRENCY EXCHANGE USD/CHF VARIABLE PAYOUT
CONTRACTS

(a) - (e) [unchanged]
(f) PAYOUT CRITERION - The Payout Criterion for each Contract will be set by
HedgeStreet at the time the Variable Payout Contracts are initially issued. For the Variable

Payout Hedgelet Contract, the Payout Criteria for the Contracts will be set as follows;

(i) WEEKLY VARIABLE USD/CHF CONTRACT

(1) CAP - The Cap shall be X + .05

(2) FLOOR - The Floor shall be X - .05

(3) DOLLAR MULTIPLIER - The Dollar Multiplier shall be 500.

(4) In each case, “X” equals the last USD/CHF price, rounded to the
nearest 0.01, as reported in the USD/CHF foreign currency market at 5PM ET on the
previous business day before the Weekly Variable USD/CHF Contract is listed for trading

on HedgeStreet.

(ii) [except for renumbering, this rule is unchanged]
44) (iii) [except for renumbering, these rules are unchanged]
(g) - (0) [unchanged]
RULE 12.34 GASOLINE VARIABLE PAYOUT CONTRACTS
(a) - (e) [unchanged]
(f) PAYOUT CRITERION - The Payout Criterion for each Contract will be set by
HedgeStreet at the time the Variable Payout Contracts are initially issued. For the Variable

Payout Hedgelet Contract, the Payout Criteria for the Contracts will be set as follows;

(i) WEEKLY VARIABLE GASOLINE CONTRACT

(1) CAP - The Cap shall be X + $0.25

(2) FLOOR - The Floor shall be X - $0.25

1825 S. Grant Street

Suite 500

‘San Mateo, CA 94402

Tet: 650.638.3500
www.hedgestreet.com Fox: 650.638.3501


HEDGE
Street.

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

(i) WEEKLY VARIABLE SILVER CONTRACT

(1) CAP - The Cap shall be X + 25.

(2) FLOOR - The Floor shall be X - 25.

(3) DOLLAR MULTIPLIER - The Dollar Multiplier shall be 1.

(4) In each case, “*X” equals the last reported Expiration Value of Silver,
rounded to the nearest five cents (5), as reported by the Source Agency.

9 (ii) MONTHLY VARIABLE SILVER CONTRACT
(1) - (3) [unchanged]

(4) In each case, “Z” equals the last Expiration Value of Silver, rounded to
the nearest five cents (5), as reported by the Source Agency.

G¥ (iii) [except for renumbering, this rule is unchanged]
RULE 12.38 — RULE 12.50 [unchanged]
RULE 12.51 NATURAL GAS VARIABLE PAYOUT CONTRACTS
(a) - (e) [unchanged]
(f) PAYOUT CRITERION - The Payout Criterion for each Contract will be set by
HedgeStreet at the time the Variable Payout Contracts are initially issued. For the Variable

Payout Hedgelet Contract, the Payout Criteria for the Contracts will be set as follows;

(i) WEEKLY VARIABLE NATURAL GAS CONTRACT

(1) CAP - The Cap shall be X + $2.00.

(2) FLOOR - The Floor shall be X - $2.00.

(3) DOLLAR MULTIPLIER - The Dollar Multiplier shall be 10.

1825 S. Grant Street

Suite 500

San Mateo, CA 94402

Tel: 650.638.3500
www.hedgestreet.com Fax: 650.638.3501


HEDGE
Street.

January 30, 2006

VIA EMAIL: secretary@ecftc.gov

Ms. Jean A. Webb

Secretary of the Commission

Commodity Futures Trading Commission
3 Lafayette Centre

1155 21st Street, N.W.

Washington, D.C. 20581

RE: Certification: HedgeStreet Temporarily Delisting Certain Monthly
Contracts and adding New Weekly Contracts - Submission pursuant to
Commission Regulation §40.6

Dear Secretary Webb:

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 temporarily delist certain monthly contracts in order to list
weekly contracts of the same Class.

Delisting of Monthly Contracts

HedgeStreet intends to delist the following Classes of Monthly Contracts until a later date
in the future.

Binary Contract | Mortgage Rate (30- Year FRM) | January 26, 2006
7230 Variable Contract | Currency Exchange EUR/USD | January 31, 2006
1231 Variable Contract _| Currency Exchange GBP/USD | January 31, 2006
1232 Variable Contract | Currency Exchange USD/VEN | January 31, 2006
1233 Variable Contract | Currency Exchange USD/CHF | January 31, 2006
1234 Variable Contract | Gasoline Tanuary 30, 2006
1235 Variable Contract | Gold Tanuary 31, 2006
1236 Variable Contract | Crude Oi! January 31, 2006
12.37 Variable Contract Silver January 31, 2006
12.54 Variable Contract | Natural Gas Tanuary 31, 2006

www.hedgestreet.com

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



HEDGE
Street.

(g) — (0) [unchanged]

RULE 12.68 —- RULE 12.78 [unchanged]

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

1825 S. Grant Street

‘Suite 500

‘San Mateo, CA 94402

Tet 650.698.9500
www.hedgestreet.com Fax: 650.638.3501



HEDGE
Street.

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

(i) WEEKLY VARIABLE CRUDE OIL CONTRACT

(1) CAP - The Cap shall be X + $15.

(2) FLOOR - The Floor shall be X - $15.

(3) DOLLAR MULTIPLIER - The Dollar Multiplier shall be 1.

(4) In each case, “X” equals the last reported Expiration Value of Crude
Oil, rounded to the nearest dollar ($1.00), as reported by the Source Agency.

@ (ii) MONTHLY VARIABLE CRUDE OIL CONTRACT
(1) - (3) [unchanged]

(4) In each case, “Z” equals the last Expiration Value of Crude Oil.
rounded to the nearest dollar ($1.00), as reported by the Source Agency.

iii) QUARTERLY VARIABLE PAYOUT CRUDE OIL
CONTRACT

(1) - (3) [unchanged]

(4) In each case, “ZZ” equals the last Expiration Value of Crude Oil as
reported by the Source Agency.

Gil) (iv) YEAR-END VARIABLE PAYOUT CRUDE OIL
CONTRACT

() - (3) [unchanged]

(4) In each case, “A” equals the last Expiration Value of Crude Oil, as
reported by the Source Agency.

¥}-(v) [except for renumbering, this rule is unchanged]
RULE 12.37 SILVER VARIABLE PAYOUT CONTRACTS

(a) - (e) [unchanged]

1826 S. Grant Street
Suite 500
San Mateo, CA 94402
Tek 650.698.9500
www.hedgestreet.com Fax: 650.638.3501



HEDGE
Street.

EXHIBIT A
(Rule additions are underlined and rule deletions are stricken out.)

RULE 12.30 CURRENCY EXCHANGE EUR/USD VARIABLE PAYOUT
CONTRACTS

(a) - (e) [unchanged]

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

Payout Hedgelet Contract, the Payout Criteria for the Contracts will be set as follows;

(i) WEEKLY VARIABLE EUR/USD CONTRACT

(1) CAP - The Cap shall be X + 0.05

(2) FLOOR - The Floor shall be X - 0.05

(3) DOLLAR MULTIPLIER - The Dollar Multiplier shall be 1000.

(4) In each case, “X” equals the Jast EUR/USD price, rounded to the
nearest 0.01, as reported in the EUR/USD foreign currency market at 5PM ET on the
previous business day before the Weekly Variable EUR/USD Contract _is listed for trading

on HedgeStreet.

@ (ii) [except for renumbering, this rule is unchanged]
i) (iii) [except for renumbering, these rules are unchanged]
(g) - (0) [unchanged]

RULE 12.31 CURRENCY EXCHANGE GBP/USD VARIABLE PAYOUT
CONTRACTS

(a) - (e) [unchanged]

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

1826 S, Grant Street
Suite 500

‘San Mateo, CA 94402
Tek 650.698.3500

www.hedgestreet.com Fax: 650.638.3501


HEDGE
Street.

HedgeStreet intends to make these amendments effective as of January 31, 2006.
No contracts that have open interest will be affected by these amendments.

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

HedgeStreet certifies that such action complies with the requirements of the Act and the
tules and regulations promulgated 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: Tom Leahy — CFTC
Phil Colling - CFTC
Clarissa Manansala — HedgeStreet, Inc.

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


HEDGE
Street.

Listing of New Weekly Instruments

HedgeStreet will be listing new weekly contracts in accordance with the following listing
schedule and the rules added in Exhibit A. Since the following Weekly Contracts will
commence trading in the middle of the week, the listing cycle for such Contracts during the
week of January 30, 2006 will be shortened. Commencing on Monday, February 6, 2006,
all Weekly Contracts will commence trading in accordance with HedgeStreet Rules.

a
Commence trading on 1/31/06 and
expire on 2/2/06. Contract to be re-
listed in accordance with HedgeStreet
Rules on 2/3/06.

12.30 Variable Contract | Currency Exchange EUR/USD Commence trading on 2/1/06 and
expire on 2/3/06. Contract to be re-
listed on 2/6/06 in accordance with
HedgeStreet Rules on 2/6/06.

12.31 Variable Contract | Currency Exchange GBP/USD Commence trading on 2/1/06 and
expire on 2/3/06. Contract to be re-
listed on 2/6/06 in accordance with
HedgeStreet Rules on 2/6/06.

12.32 Variable Contract. | Currency Exchange USD/YEN Commence trading on 2/1/06 and
expire on 2/3/06. Contract to be re-
listed on 2/6/06 in accordance with
HedgeStreet Rules on 2/6/06.

12.33 Variable Contract | Currency Exchange USD/CHF Commence trading on 2/1/06 and
expire on 2/3/06, Contract to be re-
listed on 2/6/06 in accordance with
HedgeStreet Rules on 2/6/06.

12.34 Variable Contract |" Gasoline Commence trading on 1/31/06 and
expire on 2/6/06 and therefore, has a
listing cycle in accordance with
HedgeStreet Rules.

12.35 Variable Contract | Gold Commence trading on 2/1/06 and
expire on 2/3/06. Contract to be re-
listed in on 2/6/06 accordance with
HedgeStreet Rules on 2/6/06.

12.36 Variable Contract | Crude Oil Commence trading on 2/1/06 and
expire on 2/3/06. Contract to be re-
listed in on 2/6/06 accordance with
HedgeStreet Rules on 2/6/06.

12.37 Variable Contract} Silver Commence trading on 2/1/06 and
expire on 2/3/06. Contract to be re-
listed in on 2/6/06 accordance with
HedgeStreet Rules on 2/6/06.

12.51 Variable Contract | Natural Gas Commence trading on 2/1/06 and
expire on 2/3/06, Contract to be re-
listed in on 2/6/06 accordance with
HedgeStreet Rules on 2/6/06.

Binary Contract

1825 S, Grant Street

Suite 500

‘San Mateo, CA 94402

Tel: 650.638.3500
www.hedgestreet.com Fax: 650.638.3501