itreet
February 9, 2007

VIA EMAIL: secretary@cftc.gov

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 Payout Criteria for the
Currency Exchange USD/YEN Binary Contracts by offering a new Weekly
Contract Duration; and Re-lists for trading the Weekly Currency Exchange
EUR’ USD Binary Contracts — Submission pursuant to Commission
Regulation §40.6(a)

Dear Acting Secretary Donovan:

Pursuant to Section Sc(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 its intent to a) list new Weekly Binary contracts for the Currency
Exchange USD/YEN Binary Contracts pursuant to HedgeStreet Rule 12.23; and b) re-list
for trading the Weekly Currency Exchange EUR/ USD Binary Contracts pursuant to
HedgeStreet Rule 12.21 [the contracts referenced in (a)-(b) will be collectively known as
the “Contracts”}.

HedgeStreet intends to implement the changes in all of the above-referenced Contracts at
the start of business on Monday, February 12, 2007.

All amendments to the above-referenced Contracts are defined in Exhibit A. Any rule
deletions are stricken out while the amendments and/or additions are underlined.

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

ce: Tom Leahy — CFTC
Phil Colling - CFTC

1825 8. Grant Street
San Mateo, CA 94402

Tel: 650.838.3800
wwrw.hedgestreet.com Fax: 650.638.3501



HEDGE
Street

Clarissa Manansala — HedgeStreet , Inc.

1825 8. Grant Street
Suite 500
‘San Mateo, CA 94402
Tet: 650.638.3500
www.hedgestrest.com Fax: 650.638.3501


Exhibit A

HEDGE
Street
EXHIBIT A

Amendments to Rule 12.23 only
(The following new Rule additions are underlined and deletions are stricken out)

RULE 12.23 CURRENCY EXCHANGE USD/ YEN BINARY HEDGELET
CONTRACTS

(a) - (e) [unchanged]

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

(i) [unchanged]

(ii) WEEKLY USD/ YEN BINARY CONTRACTS

(1) Binary Hedgelet Contract 1: One Contract will have a Payout Criterion
of greater than Y (rounded to the nearest 0.005) — 1.50.

(2) Binary Hedgelet Contract 2: One Contract will have a Payout Criterion
of greater than Y (rounded to the nearest 0.005) ~ 1.0.

(3) Binary Hedgelet Contract 3: One Contract will have a Payout Criterion
of greater than Y (rounded to the nearest 0.005) ~ 0.50.

(4) Binary Hedgelet Contract 4: One Contract will have a Payout Criterion
of greater than Y (rounded to the nearest 0.005).

(5) Binary Hedgelet Contract 5: One Contract will have a Payout Criterion

of greater than Y (rounded to the nearest 0.005) + 0.50.

(6) Binary Hedgelet Contract 6: One Contract will have a Payout Criterion

of greater than Y (rounded to the nearest 0.005) + 1.0.

(7) Binary Hedgelet Contract 7: One Contract will have a Payout Criterion
of greater than Y (rounded to the nearest 0.005) + 1.50.

(8) Ineach case, “Y” equals the last USD/YEN price rounded to the nearest
0.005 as reported by the Source Agency.

+4) (iii) [except for renumeration, this rule is unchanged]
(g) - (0) [unchanged]

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

1625 9. Grant Street

Sulte 500

San Mateo, CA 94402

Tel: 650.638.3500
www .hedgestreet.com Fax: 650.638.3501