ie EURONEXT

FOIA CONFIDENTIAL TREATMENT REQUEST

23 October 2019

Via E-mail to: FOlAsubmissions@cftc.gov

Assistant Secretary of the Commission for FOI,
Privacy and Sunshine Acts Compliance
Commodity Futures Trading Commission
Three Lafayette Centre

1155 21st Street,

NW Washington, DC 20581

201-418-5000

Re: FOIA Confidential Treatment Request in Connection with Euronext Amsterdam Foreign Board of
Trade Application.

Dear Sir or Madam:

Euronext Amsterdam N.V. ("Submitter") hereby respectfully requests that the Commodity Futures Trading
Commission (the "CFTC") accord confidential treatment under 17 C.F.R. §145.9 to those portions of the
exhibits to its application for registration as a foreign board of trade on Form FBOT (including the exhibits
and supplements thereto), dated 13 July 2018, which are provided in redacted form hereto for illustrative
purposes. This request is submitted pursuant to CFTC Rules 48.5 and 48.6, and specifically relates to:

Exhibits?

D-1(1): the paragraphs under “common customer gateway” and “universal trading manager (UTM)”;
D-1(2): the first two paragraphs including the chart and the paragraphs under “automated throttles”;
D-1(3): the full content;

D-1(12): the paragraphs starting from the third one included;

D-2(3): the full content;

D-2(5) : the last two paragraphs;

D-2(7): the paragraphs starting from the second one included;

E-6: the fifth paragraph including the chart;

F(2) (ii): the second paragraph;

F(2) (vii): the paragraphs under “Systems and Arrangements for the Continuous Monitoring of Trading”
and “Cross Border”;

G-1: the first, fifth and sixth paragraphs;

1 For the purpose of identifying paragraphs , the numbering does not include the requirements in bold

Euronext N.V.

Beursplein 5 | 1012 JWAmsterdam | The Netherlands

P.. Box 19163 | 1000 GD Amsterdam | The Netherlands

431 (0120 721 4400

www.euronext.com ‘TRADE REGISTER: 60234520



G-2(3) the second paragraph,

G-2(4). the last paragraph,

G-2(6) the paragraphs starting from the second one included,
G-2(9). the sixth and seventh paragraphs,

G-4 the second paragraph,

Appendices
Appendix 7 “Guidance on documented procedures”,

Certificate of good standing

The certificate was the specific attention of the CFTC and is marked strictly confidential It should not be
posted on the website,

and all information derived therefrom (collectively, the "Confidential Information")

This request for confidential treatment 1s made pursuant to 17 C F.R. §145.9(d)(I) because Submitter
believes that the Confidential Information ts covered by one or more exemptions in the Freedom of
Information Act (the "FOIA") (5 U S.C §552(b)) and is therefore exempt from the CFTC's public disclosure
requirements pursuant to 17 C F.R. §145 5 In palticular, 5 USC §552(b)(4) and 17 C.F.R §145 9(d)(I)(11)
exempts disclosure that would reveal the Submitter's trade secrets or confidential commercial or financial
information. Submitter believes that the Confidential Information contains confidential commercial and
financial information as well as proprietary information regarding business procedures and systems that
should be protected from public disclosure pursuant to this exemption. Confidential treatment is
requested for a period of five years

This request 1s not to be construed as a waiver of any other protection from disclosure or confidential
treatment accorded by law, and Submitter will rely on and invoke any such confidentiality protection
Submitter requests that the CFTC advise the undersigned, pursuant to 17 C.F.R. §145.9(e)(I), in advance
of any disclosure of the Confidential Information pursuant to the FOIA, so that this request for confidential
treatment may be substantiated

If you should have any questions or comments or require further information, please do not hesitate to
contact the undersigned at +32 2 620 1580 or by email to ryezek@euronext.com

Very truly yours,

R Jezek
Group Head of Regulation & Government Affairs, Euronext

cc’ Mr Jonathan M Lave, Division of market oversight