HEDGE
Street
(h) REPORTING LEVEL - The Reporting Level for the USD/CHF Binary
Hedgelets shall be 425,00 12,500 Contracts.
(i) - (1) [unchanged]

(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 USD/CHF Binary Contract is $40 $100.

(n) - (0) [unchanged]
RULES 12.64-12.77 [unchanged]

RULE 12.78 CURRENCY EXCHANGE USD/CAD BINARY HEDGELET
CONTRACTS

(a) — (f) [unchanged]

(g) MINIMUM TICK ~ The Minimum Tick size for the USD/CAD Binary
Hedgelets shall be $0.05 $0.50.

(h) REPORTING LEVEL - The Reporting Level for the USD/CAD Binary
Hedgelets shall be 425,000 12,500 Contracts.

(i) — (1) [unchanged]

(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 USD/CAD Binary Contract is $40 $100.

(n) — (0) [unchanged]

RULE 12.79 - 12.86 [unchanged]

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

1625 S. Grant Street

Suite 500

San Mateo, CA 94402

Tel: 650.638.3500
www.hedgestreet.com Fax: 650.638.3501


HEDGE
Street

(a) — (f) [unchanged]

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

(h) REPORTING LEVEL ~ The Reporting Level for the GBP/USD Binary
Hedgelets shall be 425,000 12,500 Contracts.

(i) — (1) [unchanged]

(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 GBP/USD Binary Contract is $40 $100.

(n) — (0) [unchanged]
RULE 12.62 CURRENCY EXCHANGE USD/YEN BINARY HEDGELET
CONTRACTS

(a) — (f) [unchanged]

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

(h) REPORTING LEVEL — The Reporting Level for the USD/YEN Binary
Hedgelets shall be 425,000 12,500 Contracts.

(i) — () [unchanged]

(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 USD/YEN Binary Contract is $40 $100.

(n) - (0) [unchanged]

RULE 12.63 CURRENCY EXCHANGE USD/CHF BINARY HEDGELET
CONTRACTS

(a) - (f) [unchanged]

(g) MINIMUM TICK - The Minimum Tick size for the USD/CHF Binary
Hedgelets shall be $9-05 $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 31, 2006

VIA EMAIL: scerctary@cftc.gov

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

Commodity Futures Trading Commission
3 Lafayette Centre

1155 21st Street, N.W.

Washington, D.C. 20581

RE: Rule Certification: HedgeStreet® a) Amends Rule 1.1(a); and b) Intends to
Increase the Maximum Settlement Value for Various Binary Contracts to
$100; Submission made pursuant to Commission Regulation §40.6(a)

Dear Acting Secretary Donovan:

Pursuant to Section Sc(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 amend the definition of Rule 1.1(a) in order to broaden the
definition of the term “Settlement Value” as it relates to all Binary Hedgelet Contracts.

Additionally, HedgeStreet intends to increase the maximum Settlement Value of the
following Binary Contracts (“Contracts”) from $10 to $100:

NEW NEW
c HedgeStreet . Effective Maximum oe
‘ategory Rule Asset/ Duration Date Settlement Minimum
Tick Size
Value
12.60 Daily (12PM, 3PM, 8PM ET
CLOSE) & Weekly EUR/USD | 11/01/06 $100] $0.50
12.61 Daily (12PM, 3PM, 8PM ET
CLOSE) GBP/USD 11/01/06 $100 $0.50
Currencies | 12-6 CLOSE) USDIYEN SPMET | 11/01/06 $100} $0.50
12.63 Daily (12PM, 3PM, 8PM ET
CLOSE) USD/CHF 11/01/06 $100 $0.50
12.78 Daily (12PM, 3PM, 8PM ET
CLOSE) USD/CAD 11/01/06 $100 $0.50

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


HEDGE
Street

As a result of the increase in the maximum Settlement Value amount, HedgeStreet is
amending the reporting level for these Contracts and the Minimum Tick size in order to
accommodate the larger maximum Settlement Value.

HedgeSteet will first issue the Contracts with the increased Settlement Value and
Minimum Tick size on Wednesday, November 1, 2006. Since the current Contracts that
have a Settlement Value of $10 and a Minimum Tick of $.05 have a Last Trade Date of
Tuesday, October 31, 2006, there will be no open interest in such Contracts upon the close
of business on Tuesday, October 31, 2006.

The amendments for these Contracts are defined in Exhibit A. The rule deletions are
stricken out and 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


HEDGE
Street
EXHIBIT A

Amendments to Rules 1.1, 12.60, 12.61, 12.62, 12.63, and 12.78
(The following new Rule additions are underlined and deletions are stricken out)

RULE 1.1 DEFINITIONS
When used in these Rules:

(a) “Binary Hedgelet Contract” means the right to receive a fixed
Settlement Value ef $40 per contract, from HedgeStreet on the Settlement Date
dependent upon whether you are holding a long position or short position in a
Binary Hedgelet. If you are holding a long position in a Binary Hedgelet, you have
the right to receive a fixed Settlement Value from HedgeStreet on the Settlement
Date, if, and only if, the Binary Contract’s Payout Criteria encompasses the
Expiration Value at Expiration. Conversely, if you are holding a short position in a
Binary Hedgelet, you have the right to receive a fixed Settlement Value if, and only
if, the Binary Contract’s Payout Criteria does NOT encompass the Expiration Value
at Expiration.

CHAPTER 2 — CHAPTER 11 [unchanged]

RULE 12.60 CURRENCY EXCHANGE EUR/USD BINARY HEDGELET
CONTRACTS

(a) — (f) [unchanged]

(g) MINIMUM TICK — The Minimum Tick size for EUR/USD Binary
Hedgelets shall be $8-05 $0.50.

(h) REPORTING LEVEL -— The Reporting Level for the EUR/USD Binary
Hedgelets shall be 425,009 12,500 Contracts.

(i) — (I) [unchanged]

(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 EUR/USD Binary Contract is $40 $100.

(n) — (0) [unchanged]

RULE 12.61 CURRENCY EXCHANGE GBP/USD BINARY HEDGELET
CONTRACTS

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