EXHIBIT B

HEDGE DRAFT
Street

(6) Binary Hedgelet Contract 6: One Contract will have a Payout Criterion
of greater than X (rounded to the nearest 2.5 cents) + 2.5.

(7) Binary Hedgelet Contract 7: One Contract will have a Payout Criterion
of greater than X (rounded to the nearest 2.5 cents) + 5.

(8) Binary Hedgelet Contract 8: One Contract will have a Payout Criterion
of greater than X (rounded to the nearest 2.5 cents) + 7.5.

(9) Binary Hedgelet Contract 9: One Contract will have a Payout Criterion
of greater than X (rounded to the nearest 2.5 cents) + 10.

(10) In each case above, ““X” is measured in U.S. cents and equals the last
Copper value, as reported by the Source Agency.

(g) MINIMUM TICK — The Minimum Tick size for the Copper Binary Hedgelets
shall be $0.01.

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

(i) POSITION LIMIT — The Position Limits for the Copper Binary Hedgelets shall
be 3,000 Contracts.

G) LAST TRADING DATE ~ The Last Trading Date in a Series is the same date
as the Expiration Date.

(k) SETTLEMENT DATE - The Settlement Date will be the date on which the
Copper Settlement Price is released by the Source Agency.

(1) EXPIRATION DATE — The Expiration Date of the Contract will be the date on
which the Copper Settlement Price is released by the Source Agency.

(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 for an in
the money Copper Binary Contract is $10.

(n) EXPIRATION VALUE — The Expiration Value is the price of Copper as
calculated by the Source Agency on the Expiration Date.

(0) CONTINGENCIES ~ If no level is actually announced on the Expiration Date
due to a delay, postponement or otherwise in such release announcement by the Source
Agency, the Settlement Date will be delayed until the Underlying number is released for
that Series.

*** Tend Rulebook] ***


HEDGE
Street
April 27, 2006

VIA EMAIL: secretary@eftc.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 files Terms and Conditions for new Binary Hedgelet
Contracts — Submission pursuant to Commission Regulations §40.2 and §40.6

Dear Secretary Webb:

Pursuant to Section Sc(c)(1) of the Commodity Exchange Act, as amended (“Act”), and §40.2
and §40.6(a) of the regulations promulgated by the Commodity Futures Trading Commission (the
“Commission’’) under the Act (the “Regulations”), HedgeStreet, Inc. (“HedgeStreet”) hereby
submits to the Commission the terms and conditions for Copper Binary Hedgelet Contracts
(“Contracts”). HedgeStreet describes these Contracts in accordance with Commission Regulation
§40.2 under Exhibit A. HedgeStreet has also included under Exhibit B new HedgeStreet Rule
12.77 to reflect all of the terms and conditions of the new Contracts in accordance with
Commission Regulation §40.6.

HedgeStreet intends to list these contracts and implement these mule additions at the start of
business on Friday, April 28, 2006.

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

HedgeStreet hereby certifies that the Contracts and clearing of the Contracts, including all rules
defining the terms and conditions of said Contracts contained herein, complies with the Act and
the Regulations.

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

Sincerely,
Stephanie Ford
Vice President, Legal & Compliance

ce: Tom Leahy — 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 DRAFT
Street
EXHIBIT A
COPPER BINARY HEDGELET CONTRACTS
Scope

The provisions of these rules shall apply to all Copper Hedgelet Contracts bought and sold on
HedgeStreet.

Underlying

The Underlying for this Class of Contracts is the Copper price per pound (in US 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 contracts currently trading
in the COMEX Division on the New York Mercantile Exchange (NYMEX®)".

Copper, exhibiting high electrical and thermal conductivity as well as high resistance to
corrosion, is a major industrial metal, ranking third after iron and aluminum in terms of quantities
consumed. Copper demand is closely linked to industrial growth in the economy as well as global
economic growth. Copper Hedgelets allow traders to speculate the degree to which the price of
Copper will increase or decrease, or, hedge against changes in future Copper prices or inflation.
Employee Trading Policy — Please refer to the HedgeStreet Rulebook.

Safeguards Against Early Release — Copper Futures are traded by open-outcry and electronically
on the COMEX Division of the NYMEX and therefore are not subject to early release.

Source Agency — The Source Agency is HedgeStreet.

Cash Market — There is currently a cash market for Copper.

Publication —- The Copper price is calculated each day by HedgeStreet after the Copper futures
contract stop trading in the COMEX Division on NYMEX, which is at about 1:00 pm ET each
day.

HedgeStreet will also be publishing the Expiration Value on its website on the Expiration Date.

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

‘ Supra, at fn i
* Supra, at fi.


EXHIBIT B

HEDGE DRAFT
Street
EXHIBIT B

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

RULE 12.77 COPPER BINARY HEDGELET CONTRACTS

(a) SCOPE ~ These Rules shall apply to the Class of Contracts referred to as the
Copper Binary Hedgelet Contracts issued by HedgeStreet.

(b) UNDERLYING ~— The Underlying for this Class of Contracts is the Copper
price per pound (in US 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 contracts currently trading in the COMEX Division on the
New York Mercantile Exchange (NYMEX®)"*.

(c) SOURCE AGENCY — The Source Agency is HedgeStreet.

(d) TYPE — The type of Contract is a Binary Hedgelet Contract.

(e) ISSUANCE - For each planned release by the Source Agency of the
Underlying, HedgeStreet will issue various Hedgelet Contracts, each of a different Series.
A new issuance of Hedgelet Contracts will commence no later than two (2) business days

following the Expiration Date.

(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 Copper Binary
Hedgelet Contract, the Payout Criteria for the Contracts will be set as follows:

(i) SPOT COPPER BINARY CONTRACTS

(1) Binary Hedgelet Contract 1: One Contract will have a Payout Criterion
of greater than X (rounded to the nearest 2.5 cents) - 10.

(2) Binary Hedgelet Contract 2: One Contract will have a Payout Criterion
of greater than X (rounded to the nearest 2.5 cents) - 7.5.

(3) Binary Hedgelet Contract 3: One Contract will have a Payout Criterion
of greater than X (rounded to the nearest 2.5 cents) - 5.

(4) Binary Hedgelet Contract 4: One Contract will have a Payout Criterion
of greater than X (rounded to the nearest 2.5 cents) - 2.5.

(5) Binary Hedgelet Contract 5: One Contract will have a Payout Criterion
of greater than X (rounded to the nearest 2.5 cents).

27 Supra, at fn 1.
28 Supra, at fn 2.