M5 N30 Al 9:06

HEDGE
Street

OFC. OF TH

June 29, 2005

VIA EMAIL: secretary @cfic.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: Trading Fees Discounted/ Quarterly Maintenance Fee Eliminated/
HedgeStreet Free Trade Promotional Offer — Extension

Dear Secretary Webb:

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 submits to
the Commission i) changes to trading fees; ii) the elimination of the Quarterly Account
Maintenance Fee; and iii) the extension of the 30 Day Free Trading Program..

e Effective July 1, 2005 — HedgeStreet trading fees and the range of Hedgelets
for which the trading fees apply will be adjusted such that:

Number of Hedgelets Traded Trading Fees

Up-te100 Up to 30 $5.00-flat fee $1.50 flat fee
401-1000 31-1000 $0.05 per Hedgelet (unchanged)
1001+ (unchanged) Discounts apply (unchanged)

e Effective July 1, 2005 — Quarterly Account Maintenance Fee Plan of $10 which
was originally submitted to the Commission on November 30, 2004 — will no
longer be imposed; and

e Effective July 1, 2005 — HedgeStreet plans to extend its Special 30 Day Free
Trade Promotional Offer (the “Promotion”). For the purposes of this extension,
HedgeStreet is relying on its filing (which introduces the Promotion’s terms and
conditions) previously submitted to the Commission on January 28, 2005. The
same filing was later amended to extend the Program Period an additional three
months (April 1t— June 30") on March 22, 2005.

The Promotion
As a fully electronic, non-intermediated, retail-based contract market, HedgeStreet is

primarily focused on the retail investor and optimizing his/her trading experience as an
1825 S. Grant Street
Suite 500
‘San Mateo, CA 94402
Tel: 650.638.3500
www.hedgestreet.com 1 Fax: 650.638.3501


Sireet

exchange member. By providing an incentive for members to trade, HedgeStreet
continues to implement ways of increasing market liquidity while gaining new market
data in the products currently offered on the exchange.

There is a limit of one (1) member participant per household.

Regulatory Issues
HedgeStreet hereby certifies that the Promotion complies with the Commodity

Exchange Act, as amended, and the Commissions regulations adopted thereunder.

The purpose of this letter is to notify the Commission of HedgeStreet’s intention to a)
discount the trading Fees and adjust the range of Hedgelets for which such trading fees
apply; b) eliminate the Quarterly Account Maintenance Fee Plan; and c) extend the
expiration of the Promotion Period from Thursday, June 30, 2005 to the end of business
on Friday, September 30, 2005.

Should you have any questions or require additional information, please do not hesitate
to contact the undersigned at (650) 638-3511 or sford@hedgestreet.com.

Sincerely,

Stephanie Ford
Vice President, Legal & Compliance

cc: Clarissa Manansala — HedgeStreet, Inc.

1825 S. Grant Street

‘San Mateo, CA 04402
Tel: 650.638.3500
www.hedgestreet.com Fax: 650.638.3501