45 Lansing St, 

#2205, 

San Francisco, CA, 94105 

FOIA CONFIDENTIAL TREATMENT REQUEST 

Pursuant to 17 C.F.R. §§ 38.3(a)(3), 38.3(a)(4), 145.5 and 145.9

December 27th, 2019 

VIA ELECTRONIC MAIL 

Assistant Secretary for FOI, Privacy 

and Sunshine Acts Compliance 

Commodity Futures Trading Commission 

Three Lafayette Center 

1155 21st Street, N.W. 

Washington, D.C. 20581 

FOIAsubmissions@cftc.gov

Re: FOIA Confidential Treatment Request 

Dear Sir or Madam, 

KalshiEX LLC (“Submitter”) has on this date provided the documents described in Appendix A to this 

letter (the “Confidential Submission”) through the Commission website and via electronic mail to the 

Division of Market Oversight. 

In accordance with the provisions of Commission Regulations 38.3(a)(3), 38.3(a)(4), 145.5 and 145.9, 

Submitter hereby requests confidential treatment of the Confidential Submission. Confidential treatment 

is requested, inter alia, on the grounds that the Confidential Submission contains data and information 

which would separately disclose business transactions and trade secrets that may not be disclosed to third 

parties, as provided in Section 8(a) of the Commodity Exchange Act and Commission Regulation 

145.5(c)(1). Confidential treatment additionally is requested on the grounds that the Confidential 

Submission is exempt from disclosure under paragraph (b)(4) of the Freedom of Information Act 

(“FOIA”) and Commission Regulations 145.5(d) and 145.9(d)(1)(ii) because it contains commercial and 

financial information that is confidential and would be of material assistance to competitors of Submitter. 

Doc ID: 0fefcc7500bdb99f149218d4af00ae474ecc6718
In accordance with the provisions of paragraph (d)(5) of Regulation 145.9, Submitter requests that the 

Confidential Submission be afforded confidential treatment in perpetuity. Submitter understands that if 

the Commission receives a FOIA request for the Confidential Submission, Submitter will be notified of 

such request in accordance with the Commission’s regulations and be asked to submit, within ten business 

days, a detailed written justification for confidential treatment of the Confidential Submission. In such an 

event, Submitter requests that Commission staff telephone or email the undersigned rather than rely upon 

United States mail for such notice. 

If the Commission or its staff transmits any of the Confidential Submission to another federal agency, 

Submitter requests that you forward a copy of this letter to any such agency with the Confidential 

Submission and further requests that you advise any such agency that Submitter has requested that this 

material be accorded confidential treatment. 

The requests set forth in the preceding paragraphs also apply to any memoranda, notes, transcripts or 

other writings of any sort whatsoever that are made by, or at the request of, any employee of the 

Commission (or any other federal agency) and which (1) incorporate, include or relate to any aspect of the 

Confidential Submission; or (2) refer to any conference, meeting, or telephone conversation between 

Submitter, its current or former employees, representatives, agents, auditors or counsel on the one hand 

and employees of the Commission (or any other government agency) on the other, relating to the 

Confidential Submission. 

If you should have any questions or comments or require further information, please do not hesitate to 

contact the undersigned at luana@kalshi.com or 412-353-5401. 

Sincerely, 

Luana Lopes Lara 

Chief Operating Officer 

Doc ID: 0fefcc7500bdb99f149218d4af00ae474ecc6718
Appendix A

KalshiEX LLC requests that the following information be subject to its request for confidential treatment 

pursuant to §145.9 of the Commission regulations: 

Exhibit A (Ownership) 

Exhibit B (Board and Governance) 

Exhibit C (Fitness Standards) 

Exhibit D (Organizational Structure) 

Exhibit E (Personnel Qualifications) 

Exhibit F (Staffing Requirements) 

Exhibit H (Legal Proceedings) 

Exhibit I (Narrative on Financial Resources and operating costs) 

Exhibit K (Analysis of Fees, Dues and other Charges) 

Exhibit L (Regulatory Chart) 

Exhibit N (Third Party Contracts) 

Exhibit O (Compliance) 

Exhibit P (Disciplinary and Enforcement) 

Exhibit Q (Trade System Description) 

Exhibit S (Trade Information Policy) 

Exhibit T (Clearing Representations) 

Exhibit V (Technology Questionnaire and Safeguards) 

Doc ID: 0fefcc7500bdb99f149218d4af00ae474ecc6718
Audit Trail

Title


File Name


Document ID


Audit Trail Date Format


Status

Exhibit U - Confidentiality Request

Exhibit U - Confi...y Request (1).pdf

0fefcc7500bdb99f149218d4af00ae474ecc6718

MM / DD / YYYY

Completed

12 / 27 / 2019

18:10:16 UTC

Sent for signature to Luana Lopes Lara (luana@kalshi.com)

from tarek@kalshi.net

IP: 89.249.216.4

12 / 27 / 2019

18:27:37 UTC

Viewed by Luana Lopes Lara (luana@kalshi.com)

IP: 187.82.84.13

12 / 27 / 2019

18:36:32 UTC

Signed by Luana Lopes Lara (luana@kalshi.com)

IP: 187.47.149.151

12 / 27 / 2019 The document has been completed.

18:36:32 UTC