LMX Labs, LLC d/b/a Coinbase Derivatives

December 12, 2023

VIA CFTC Electronic Portal

Mr. Christopher J. Kirkpatrick

Secretary of the Commission

Office of the Secretariat

Commodity Futures Trading Commission

Three Lafayette Centre

1155 21st Street, NW

Washington, DC 20581

Re: CFTC Regulation 40.6(a) Certification: Crypto Futures Anchor Partner

Program H1 2024

Coinbase Derivatives Submission #2023-15

Dear Mr. Kirkpatrick:

Pursuant to Commodity Futures Trading Commission (“CFTC” or “Commission”) Regulation

40.6(a), LMX Labs, LLC, d/b/a Coinbase Derivatives (the “Exchange”) hereby submits for

self-certification for its Crypto Futures Anchor Partner Program H1 2024 (the” Program”). The

purpose of the Program is to incentivize liquidity and volume in the Exchange’s products. The

terms and conditions of the Program are set forth in Exhibit A, attached hereto, and will become

effective on January 1, 2024.

Compliance with Core Principles

The Exchange has reviewed the designated contract market (“DCM”) core principles (“Core

Principles”) set forth in the Commodity Exchange Act and the CFTC rules thereunder and has

identified that the following Core Principles that may be directly implicated by the Program:

Core Principle 2 -- Compliance with Rules and Core Principle 4 -- Prevention of Market

Disruption

All trading on the Exchange, including any trading and related activity by participants under the

Program, is subject to the Exchange Rulebook (the “Rulebook”) including Chapter 5, which

prohibits fraud, non-competitive trading, market manipulation and abusive and disruptive trade

practices. Capitalized terms not otherwise defined herein are defined in the Rulebook.

Additionally, as with all trading on the Exchange, trading in the Program’s products will be

subject to monitoring and surveillance by the Market Regulation Department, which has the

authority to investigate and enforce Exchange rules, as described in Chapter 7.

Core Principle 9 -- Execution of Transactions

The Program’s products are listed for trading on the Exchange’s trading system, which provides

for efficient, competitive, and open execution of transactions pursuant to the Exchange rules.

FOIA CONFIDENTIAL TREATMENT REQUESTED BY LMX LABS LLC PURSUANT TO 17 C.F.R. PART 145
Core Principle 12 -- Protection of Markets and Market Participants

Chapters 4 and 5 of the Rulebook require all Participants, including those participating in the

Program, to observe high standards of integrity, market conduct, commercial honor, fair dealing,

and just and equitable principles of trade and prohibits, among other things, fraud,

non-competitive trading, market manipulation, and abusive and disruptive trade practices. As

with all contracts traded on the Exchange, trading in the Program’s products will be subject to

monitoring and surveillance by the Market Regulation Department and compliance with the

Program will be monitored and enforced by the Exchange.

Core Principle 18 – Recordkeeping

Records related to the Program will be maintained by the Exchange in compliance with its

recordkeeping policies and the requirements of the Commodity Exchange Act and CFTC Rules.

Certification

The Exchange is not aware of any substantive opposing views to the Program. The Exchange

certifies that the Program complies with the Commodity Exchange Act and the rules and

regulations promulgated thereunder.

The Exchange certifies that this submission has been concurrently posted on the Exchange’s

website at: https://www.coinbase.com/derivatives.

If you have any questions or require any further information, please contact me at

jane.downey@coinbase.com.

Sincerely,

/s/

Jane Downey

Chief Regulatory Officer

Attachment: Appendix A

FOIA CONFIDENTIAL TREATMENT REQUESTED BY LMX LABS LLC PURSUANT TO 17 C.F.R. PART 145
APPENDIX A

Crypto Futures Anchor Partner Program H1 2024

Program Purpose

The purpose of the Crypto Futures Anchor Partner Program H1 2024 (the “Program”) is to

support the development of the products listed below by increasing volume and liquidity in the

Exchange’s central limit order book and, therefore, benefit all Participants in the market.

Specifically, this Program aims at increasing activity from end-users.

Product Scope

Bitcoin (BTI) and Ether Futures (ETI)

1

Product (Symbol) Bitcoin (BTI) Ether (ETI)

Contract size 1 10

Contract Notional ~$25,000 ~$18,000

Min tick size ($ value) 5 index pts ($5) 0.50 pts ($5)

Eligible Participants

The Program is limited to “Market Makers” and “Professional Traders” as defined on the CDE

Fee Schedule (referred to herein as “Eligible Participants”). All applicants are subject to review

and approval by the Exchange’s onboarding team.

Program Term

The Program becomes effective on January 1, 2024 and ends on June 30, 2024.

Obligations

[Redacted]

Monitoring and Termination of Status

The Exchange will monitor each Participating Participant’s trading activity and performance and

retains the right to revoke the Participating Participant's status if it determines that an

Participating Participant failed to meet the obligations of the Program.

1 The Program shall exclude nano Bitcoin Futures and nano Ether Futures. The Exchange may in its

discretion extend the Product Scope to include any Exchange listed futures products. If extended,

reasonable notice will be provided to Eligible Participants.

FOIA CONFIDENTIAL TREATMENT REQUESTED BY LMX LABS LLC PURSUANT TO 17 C.F.R. PART 145