RECEIVED

s CFTC,
HEDGE 20 JUL 27 PM a: 4Q
Street
ur. OF THE SE
July 27, 2006 ~~ iit SECRETARIAT
4
VIA EMAIL: sceretary@efte.gov eins

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 the Definition of Underlying to and the
Reporting Levels for the Copper Binary Contracts — Submission pursuant to
Commission Regulation §40.6(a)

Dear 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 that it
intends to amend both the definition of Underlying as well as the reporting level for the Copper
Binary Contracts (the “Contracts”).

HedgeStreet is amending the definition of Underlying for the Copper Binary Contracts in order to
more clearly define the terms of the Underlying. Therefore, no Contracts with open interest are
materially affected by this amendment to the definition of Underlying.

The amendments to the Copper Binary Underlying definition and the Contract’s reporting levels are
defined in Exhibit A. Any rule deletions are stricken out while the amendments are underlined.

HedgeStreet intends to implement these rule additions on Friday, July 28, 2006.
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

cc: 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


Exhibit A

HEDGE
Street

EXHIBIT A

(The following new Rule additions are underlined and deletions are stricken out)

RULE 12.77 COPPER BINARY HEDGELET CONTRACTS
(a) [unchanged]

(b) UNDERLYING - The Underlying for this Class of Contracts is the
Copper price per pound (in U.S. cents), herein after referred to as “Copper”, as
calculated by HedgeStreet using a proprietary algorithm which takes a sampling of
prices*’ obtained from the specified Copper Futures eContracts (“CPFC”) currently
trading in the COMEX Division on the New York Mercantile Exchange
(NYMEX®)**. The CPFC prices that will be used to calculate the Underlying will
be taken from the January, March, May, July, September, or December CPFC
delivery months (“CPFC Delivery Month”). The specific delivery month that will
be used will depend on the date on which the Underlying is being calculated. For
instance, each day that the Underlying is calculated that is on or after the third
business day before the end of April and on or before the fourth business day before
the end of June, the July CPFC trade prices will be used. Each day that the
Underlying is calculated that is on or after the third business day before the end of
June and on or before the fourth business day before the end of August, the
September CPFC trade prices will be used. This process will repeat itself, so that on
the third business day before the end of the calendar month preceding each January.
March, May, July, September, and December, the CPFC trade prices to be used in
calculating the Underlying will move to the next succeeding futures month listed.

(c) - (g) [unchanged]

(h) REPORTING LEVEL — The Reporting Level for the Copper Binary
Hedgelets shall be 25 100 Contracts.

(i) - (0) [unchanged]

[remainder of page intended to be blank]

?’Supra, at fn I
28 Supra, at fn 2.

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