April 21, 2015

FOIA CONFIDENTIAL TREATMENT REQUEST

VIA Electronic Mail and Overnight Delivery

Assistant Secretary of the Commission for FOIA, Privacy and Sunshine Acts Compliance 

Commodity Futures Trading Commission

Three Lafayette Centre

1155 21st Street, N.W.

Washington, DC 20581

Via email: FOIAsubmission@cftc.gov and by overnight delivery

RE: Freedom of Information Act ("FOIA") Confidential Treatment Request for Information 

Submitted to the Commodity Futures Trading Commission ("Commission") Pursuant to 

Section 5h of the Commodity Exchange Act and Part 37 of the Regulations of the 

Commission, by Javelin SEF, LLC, as operator of a swap execution facility

To Whom It May Concern:

Javelin SEF, LLC, (“Javelin”), as operator of a temporarily registered swap execution facility, has 

submitted to the Commission Javelin’s Rule Submission 15-04 regarding Javelin’s market maker program

(Submission 150-04). 

Today Javelin submitted Submission 15-04 through the Commission’s portal and by sending a copy by 

email addressed to Mark Schlegel (mschlegel@cftc.gov). Submission 15-04 is referred to herein as the 

"Confidential Information". Javelin hereby requests that the Confidential Information be accorded 

confidential treatment on the grounds that it would reveal the Javelin's trade secrets and confidential 

commercial and/or financial information. Javelin SEF believes the financial terms of its market maker 

program are proprietary in nature, as they contain a proprietary method for calculating fees and/or rebates. 

We request this confidential treatment for an indefinite period.

We understand that if the Commission receives a FOIA request for the Confidential Information, we 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

JAVELIN SEF , LLC 

443 PARK AVENUE SOUT H, 10 T H FLOOR • NEW YORK, NE W YORK • 10016

PHONE: (212) 779 - 2300 • FAX: 646 - 588 - 2039
Assistant Secretary of the Commission for FOIA

April 21, 2015

Page 2

Information. See Commission Rule § 149.5(e)(1); see also Executive Order 12600, 52 Fed. Reg. 23781 

(June 23, 1987) (detailing pre-disclosure notification procedures under FOIA). In such event, we request 

that Commission staff telephone or e-mail the following rather than rely upon United States mail for such 

notice so that we may substantiate the foregoing request for confidential treatment in accordance with 

Part 145.9 of the Commission's regulations.

Suellen M. Galish

Senior Managing Director

General Counsel & 

Chief Compliance Officer 

Javelin SEF, LLC

443 Park Avenue South,

New York, NY 10016

Direct Dial: 646-307-5931

Email: suellen.galish@thejavelin.com

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

request that you forward a copy of this letter to any such agency with the Confidential Information and 

further request that you advise any such agency that the Javelin 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: (i) incorporate, include or relate to any aspect of 

the Confidential Information; or (ii) refer to any conference, meeting, or telephone conversation between 

the Javelin and 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 Information.

Pursuant to Part 145.9(d)(4) of the Commission's regulations, we have marked each page of the 

Confidential Information submitted to the Commission with the words "Confidential Treatment 

Requested by Javelin SEF, LLC".

JAVELIN SEF , LLC 

443 PARK AVENUE SOUT H, 10 T H FLOOR • NEW YORK, NE W YORK • 10016

PHONE: (212) 779 - 2300 • FAX: 646 - 588 - 2039