HEDGE
Street

February 27, 2007
VIA ELECTRONIC MAIL: secretary@cftc.gov

Ms. Eileen Donovan

Acting Secretary of the Commission

Commodity Futures Trading Commission _
3 Lafayette Centre

1155 21st Street, N.W.
Washington, D.C. 20581

RE: Certification: HedgeStreet Implements a New Way for the HedgeStreet
Trading System to Accept Orders from Market Makers — Submission
pursuant to Commission Regulation §40.6(a) and Commission Regulation
145.9

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 implement a new way for the HedgeStreet Trading System to
accept orders (“Quote”) from market makers in order to enhance exchange performance
which is further detailed below in Exhibit A.

There will be no impact to end-users due to the implementation of the enhancement
described in Exhibit A. If an end-user places an order that matches with a Quote, the
transaction will be maintained in the same manner that it is today.

HedgeStreet has discussed this change from Orders to Quotes for market makers with
NFA. HedgeStreet has also sent test files to NFA to ensure that it received all required
information in such files. NFA stated that no problems were encountered during its testing
of the files as there were no changes to the files NFA has been receiving since
HedgeStreet commenced trading activity. NFA noted that HedgeStreet's proposed changes
will primarily effect how HedgeStreet stores Quotes during the trading session and will
facilitate the user's order management. NFA stated that these changes will be entirely
transparent to NFA since HedgeStreet will still report Quote activity in the same manner
that HedgeStreet uses for regular Orders.

There will be no changes to any of the reports HedgeStreet currently sends to the
Commission as a result of the Quotes implementation.

Please be advised that Exhibit A to this certification contains trade secrets or confidential
commercial information of HedgeStreet. HedgeStreet has therefore petitioned for
confidential treatment to be afforded to Exhibit A pursuant to Commission Regulation 145.9
until HedgeStreet notifies the Commission that HedgeStreet, Inc., no longer regards such
information as confidential.

1825 S. Grant Street

‘San Mateo, CA 94402
Tel: 650.638.3500
www.hedgestreet.com Fax: 650.638.9501


Street

HedgeStreet intends to implement the aforementioned amendments during the week
commencing Monday, February 26, 2007.

There were no substantive opposing views expressed in approving these amendments.

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

Sincerely,

Stephanie Ford
Vice President, Legal & Compliance

ce: Clarissa Manansala — HedgeStreet, Inc.
Riva Adriance —- Commodity Futures Trading Commission

1825 S. Grant Street

Sulte 500

‘San Mateo, CA 94402

Tel: 650.638.3500
www.hedgestreet.com Fax: 650.638.3501