crypto.com | Derivatives North America

200 West Jackson Blvd., Suite 1400

Chicago, IL 60606

July 5, 2023

Via CFTC Portal Submissions

Mr. Christopher Kirkpatrick

Secretary of the Commission

Office of the Secretariat

Commodity Futures Trading Commission

3 Lafayette Centre 

1155 21st Street, N.W. 

Washington D.C. 20581

RE: Rule Certification: Nadex Amends Product Specifications for ETH UpDown 

Options and adds additional acceptable currency denominations for deposits 

and withdrawals to and from Nadex client accounts - Submission Pursuant to 

Commission Regulation §40.6(a)

Dear Mr. Kirkpatrick:

Pursuant to Section 5c(c)(1) of the Commodity Exchange Act, as amended (the 

“Act”), and §40.6(a) of the regulations promulgated by the Commodity Futures Trading 

Commission (the “Commission”) under the Act, North American Derivatives Exchange, Inc. 

(“Nadex”) hereby submits to the Commission its intent to amend Rule 12.25 by adjusting

the ETH UpDown Options contract range on a permanent basis due to changes in the 

volatility of underlying market upon which the ETH UpDown Contract is based. 

Additionally, Nadex will also be adjusting the dollar multiplier of the ETH UpDown 

Contract to better reflect market conditions. Nadex believes that adjustment to the ranges

and dollar multiplier for this contract will prove to be more suitable given market conditions. 

Additionally, Nadex is also amending a footnote to Rule 3.1 in order to allow GBP and EUR 

as additional acceptable denominations for the purposes of depositing into and withdrawing 

from a Member’s Nadex account. All amendments indicated in this submission are for the 

purpose of creating more attractive and tradeable contracts for Nadex clients.

Analysis of Nadex Rule 3.1 Amendment Compliance With Core Principles

DCM Core Principles

Nadex has identified the following DCM Core Principles as potentially being 

impacted by the additional means of funding a Nadex account: Core Principle 2 

(Compliance with Rules); Core Principle 7 (Availability of General Information); Core 

Principle 11 (Financial Integrity of Transaction).
2

Core Principle 2 requires a DCM to, among other things, establish, monitor, and 

enforce access requirements, which shall be impartial, transparent and applied in a nondiscriminatory manner. Currently, in order to be eligible for Nadex Membership and gain

access to the Nadex markets, an applicant must have an account in their name at either a US 

Financial Institution that will be used to directly fund their Nadex account, or an account at 

a Foreign Bank that will be used to fund the Nadex account through a Correspondent 

Account. The addition of allowing GBP and EUR as additional acceptable denominations 

for the purposes of depositing into and withdrawing from a Member’s Nadex account will 

be available to all Members. Nadex anticipates that providing additional denominations for 

deposit and withdrawal will increase convenience during the onboarding process and 

promote greater access to its markets. Therefore, this addition will not negatively impact 

Nadex’s ability to comply with this Core Principle. 

Core Principle 7 requires that the DCM ensure that its Rulebook is accurate, 

complete, current and readily accessible to the public, and all new or amended rules, both 

substantive and non-substantive, shall be reflected in the Rulebook on the date of 

implementation. Nadex makes its Rulebook publicly available on the Nadex website. On 

the effective date of this submission, the Rulebook will be updated and published noting the 

ability to deposit to and withdraw from a Member’s Nadex account through additional 

currency denominations. Accordingly, these amendments will not negatively affect Nadex’s 

ability to comply with this Core Principle.

Core Principle 11 requires the DCM to ensure the financial integrity of transactions 

entered into, on, or through the facilities of the DCM by, among other things, implementing 

minimum financial standards and protecting funds. All Nadex contracts are currently fully 

collateralized, and all orders are subject to a “cap-check” prior to acceptance by the 

Exchange to ensure sufficient funds exist in the Member’s account to fully collateralize the 

transaction should the order be executed. The same cap-check will be applied regardless of 

whether a Member makes a deposit directly from a US Financial Institution account, from a 

Foreign Bank account through a Correspondent Account, or from a US Financial Institution 

or Foreign Bank account through an approved registered money services business. All funds 

are held in a segregated account at Nadex’s settlement bank, identified as “Money Property 

– Cleared Swaps Proprietary Account”, which is reviewed daily by the Finance and 

Compliance Departments. Accordingly, these amendments will not negatively affect 

Nadex’s ability to comply with this Core Principle.

DCO Core Principles

Nadex has identified the following DCO Core Principles as potentially being 

impacted by the additional means of funding a Nadex account: Core Principle C (Participant 

and Product Eligibility); Core Principle F (Treatment of Funds); Core Principle L (Public 

Information).
3

Core Principle C requires a DCO to have appropriate admission and continuing 

participation requirements for clearing members that are objective, publicly disclosed, and 

risk-based. Moreover, the participation requirements shall permit fair and open access to 

the markets. As stated above, in order to gain access to the Nadex markets a Member must 

fund his/her/its Nadex account from an account in the Member’s name at a US Financial 

Institution or Foreign Bank. The additional denominations available for deposits and 

withdrawals will be available to all Members. Therefore, this addition will not negatively 

impact Nadex’s ability to comply with this Core Principle. 

Core Principle F requires a DCO to establish standards and procedures to protect and 

ensure the safety of funds belonging to its members. Nadex holds all Member funds in a 

bank account identified as “Member Property – Cleared Swaps Proprietary Account” and all 

funds are separate from Nadex’s operating funds. The account balance is reviewed daily by 

the Finance and Compliance Departments. Accordingly, these amendments will not 

negatively affect Nadex’s ability to comply with this Core Principle.

Core Principle L requires a DCO make publicly available its rules in a clear and 

comprehensive manner. Nadex makes its eligibility requirements and acceptable means of 

funding as set forth in Rule 3.1 of the Rulebook on its website, which will be updated with 

the additions discussed herein on the effective date. Accordingly, these amendments will not 

negatively affect Nadex’s ability to comply with this Core Principle.

Analysis of Nadex Rule 12.25 Amendment Compliance With Core Principles

DCM Core Principles

Nadex has identified the following Designated Contract Market (“DCM”) Core 

Principle as potentially being impacted by the amendments to Rule 12.25 discussed herein: 

Core Principle 7 Availability of General Information.

Core Principle 7 requires that the DCM ensure that its Rulebook is accurate, 

complete, current and readily accessible to the public, and all new or amended rules, both 

substantive and non-substantive, shall be reflected in the Rulebook on the date of 

implementation. Nadex makes its Rulebook publicly available on the Nadex website. On 

the effective date of this submission, the Rulebook will be updated to reflect the amendments 

to the contract specifications for all contracts that will undergo an adjustment as per this 

submission, where the strike width or strike range (in the case of UpDown contracts) and 

Dollar Multipliers for those contracts can be found. Accordingly, these amendments will not 

negatively affect Nadex’s ability to comply with this Core Principle.
4

DCO Core Principles

Nadex has not identified any Derivatives Clearing Organization (“DCO”) Core 

Principles as potentially being impacted by the amendments to Rule 12.25 discussed herein.

A complete index of the DCM and DCO Core Principles that indicates whether the 

Core Principle is applicable and addressed in the text of this submission is attached in Exhibit 

A. These Rule changes have been outlined in Exhibit B. The amendments to the Rulebook 

are set forth in Exhibit C. Any deletions are stricken out while the amendments and/or 

additions are underlined.

Nadex hereby certifies that the additions contained herein comply with the Act, as 

amended, and the Commission Regulations adopted thereunder. No substantive opposing 

views were expressed to Nadex with respect to any of these actions.

Nadex hereby certifies that notice of these amendments was posted on its website at 

the time of this filing.

In accordance with the 10-day review period set forth in Commission Regulation 

40.6(a)(3), these Rule changes will be effective as of July 19, 2023. 

Should you have any questions regarding the above, please do not hesitate to contact 

me by telephone at (312) 884-0161 or by email at kevin.dan@nadex.com.

 Sincerely, 

 Kevin J. Dan

 Chief Compliance Officer

 Chief Regulatory Officer
5

EXHIBIT A

Designated Contract Market (“DCM”) Core Principles

Core 

Principle 

Number

Core Principle Name Addressed in or Not 

Applicable to SelfCertification

1 Designation as Contract Market Not applicable

(designation granted)

2 Compliance with Rules Addressed

3 Contracts Not Readily Subject to 

Manipulation

N/A; not impacted by this 

submission

4 Prevention of Market Disruption N/A; not impacted by this 

submission

5 Position Limitations or Accountability N/A; not impacted by this 

submission

6 Emergency Authority Not applicable (Nadex 

Rulebook, 2.4 Emergency 

Rules)

7 Availability of General Information Addressed

8 Daily Publication of Trading 

Information

N/A; not impacted by this 

submission

9 Execution of Transactions N/A; not impacted by this 

submission

10 Trade Information N/A; not impacted by this 

submission

11 Financial Integrity of Transactions Addressed

12 Protection of Markets and Market 

Participants

N/A; not impacted by this 

submission
6

13 Disciplinary Procedures Not applicable (Nadex 

Rulebook, Chapter 9 Rule 

Enforcement)

14 Dispute Resolution Not applicable (Nadex 

Rulebook, 10.2 – 10.4 

Arbitration)

15 Governance Fitness Standards Not applicable (Nadex 

Rulebook, 2.2 Service 

Restrictions, 11.2 Service 

and Disciplinary History)

16 Conflicts of Interest Not applicable (Nadex 

Rulebook, 2.6 Voting, 2.9 

Trading Limitations, 11.1 

Non-Public Information, 

11.3 Voting)

17 Composition of Governing Boards of 

Contract Markets

Not applicable (internal 

review and appointment of 

directors)

18 Recordkeeping N/A; not impacted by this 

submission

19 Antitrust Considerations Not applicable

20 System Safeguards Not applicable (internal 

controls and policies in 

place)

21 Financial Resources Not applicable (capital 

requirements and quarterly 

reporting compliant)

22 Diversity of Boards of Directors Not applicable (not public 

company, internal review 

and appointment of 

directors)

23 Securities and Exchange Commission Not applicable
7
8

Derivatives Clearing Organization (“DCO”) Core Principles

Core 

Principle 

Number

Core Principle Name Addressed in or Not 

Applicable to SelfCertification

A Compliance Not applicable

B Financial Resources Not applicable (capital 

requirement and quarterly 

reporting compliant)

C Participant and Product Eligibility Addressed

D Risk Management N/A; not impacted by this 

submission

E Settlement Procedures N/A; not impacted by this 

submission

F Treatment of Funds Addressed

G Default Rules and Procedures N/A; not impacted by this 

submission

H Rule Enforcement Not applicable (Nadex 

Rulebook, Chapter 9 Rule 

Enforcement, 10.2 – 10.4 

Arbitration)

I System Safeguards Not applicable (internal 

controls and policies in 

place)

J Reporting Not applicable (Nadex 

Rulebook Chapter 8 

Member Funds)

K Recordkeeping N/A; not impacted by this 

submission

L Public Information Addressed
9

M Information Sharing N/A; not impacted by this 

submission

N Antitrust Considerations Not applicable

O Governance Fitness Standards Not applicable (Nadex 

Rulebook, 2.2 Service 

Restrictions, 11.2 Service 

and Disciplinary History, 

internal review and 

appointment of directors)

P Conflicts of Interest Not applicable (Nadex 

Rulebook, 2.6 Voting, 2.9 

Trading Limitations, 11.1 

Non-Public Information, 

11.3 Voting)

Q Composition of Governing Boards Not applicable (internal 

review and appointment of 

directors)

R Legal Risk Not applicable (Nadex 

Rulebook Chapter 6)
10

EXHIBIT B

Rule Asset Duration/Close Time Action Effective 

Date

3.1 Trading 

Members –

Applications, 

Classifications, 

and Privileges

N/A Amends footnote 3 which outlines 

acceptable currency denominations 

for deposits to and withdrawals 

from Nadex Member accounts.

7/19/2023

12.25 Ether 

Cryptocurrency 

Touch Bracket 

Variable Payout 

Contracts

All Contracts Amends the Strike Width and 

Dollar Multiplier in the product 

specification

7/19/2023
11

EXHIBIT C

Amendment of Rules 3.1 and 12.25

(The following Rule amendments are underlined and deletions are stricken out)

RULE 1.1 - 2.10 [UNCHANGED] 

RULE 3.1 TRADING MEMBERS - APPLICATIONS, CLASSIFICATIONS, AND 

PRIVILEGES

(a) To be eligible to become a Trading Member:

(i) An applicant who is an individual, must:

1) provide Nadex with any information or 

documentation Nadex deems necessary in order to verify the 

applicant’s identity, perform a criminal background check, or 

otherwise review information provided on an Application for 

Membership or by a third party provider1;

2) (A) have an account(s) in the Trading Member’s 

name with a US Financial Institution that the Trading Member will

use to fund its Nadex account at the Nadex settlement bank, and to 

receive funds from its Nadex account, or,

(B) have a verified account(s) at a Financial 

Institution or Foreign Bank (or other similarly authorized institution 

that has been vetted by Nadex and received pre-approved written

authorization from Nadex that it is an acceptable means of deposit)

held in the Trading Member’s name that the Trading Member will

authorize per transaction to deposit funds to the Trading Member’s

Nadex account at the Nadex settlement bank by means of a 

registered money services business.; or

(C) have an account(s) as described in 

subsections (A) or (B) or an account(s) in the Trading Member’s

1 Required documentation may vary depending on the applicant’s residential location. 

Specific residential locations from which Nadex may accept applications for Membership 

will be identified on the Nadex Membership application.
12

name with a Foreign Bank capable of transacting with Nadex’s 

settlement bank either directly, through a Correspondent Account, 

or other acceptable intermediary that the Trading Member will use 

to fund its Nadex account at the Nadex settlement bank, and to

receive funds from its Nadex account via one of the acceptable 

methods as stated on the Nadex website2; and

3) certify that

(A) the applicant is old enough to enter into a 

legally enforceable contract and has reached 

the required age as stated on the Membership 

Agreement;

(B) the applicant has read, understands and agrees 

to comply with the Nadex Rules, Risk 

Disclosure Statement, Terms of Use, Privacy 

Policy, and Membership Agreement;

(C) the applicant agrees to be bound by these 

Rules; and

(D)the applicant will trade only for itself and will 

not trade as an intermediary for any other 

person or entity.

(ii) An applicant that is an Entity must

(1) be organized in the United States;

(2) provide Nadex with a valid Taxpayer Identification

Number;

(3) provide Nadex with a valid legal entity identifier as 

described in Commission Regulation §45.6;

2 All funds deposited into the Trading Member’s Nadex account at the Nadex settlement 

bank shall be in any of the following currency denominations: U.S. dollars, British Pounds 

or Euro Currency. All withdrawal payments from the Trading Member’s Nadex account 

will also be made in any of the following currency denominations: U.S. dollars, British 

Pounds or Euro Currency.
13

(4) have an account or accounts in the Entity Trading

Member’s name with a Financial Institution that the Entity Trading 

Member will use to fund its Nadex account at the Nadex settlement

bank, and to receive funds from its Nadex account, via one of the 

acceptable methods as stated on the Nadex website; and

(5) designate Authorized Trader(s) to trade its account

and agree that such Authorized Trader(s) will trade only for it and 

will not trade for him/herself or as an intermediary for any other 

entity or person;

(6) designate at least one officer who is responsible for 

supervising all activities of its employees relating to transactions 

effected on Nadex or subject to Nadex Rules and provide any

information Nadex may request regarding such officer(s);

(7) agree to be bound by these Rules; and

(8) certify that

(A) the applicant is validly organized, in good 

standing, in the United States;

(B) the applicant is authorized by its governing 

body and, if relevant, documents of 

organization, to trade commodities, swaps, 

futures and options contracts, and

(C) the applicant has read, understands and 

agrees to comply with the Nadex Rules, Risk 

Disclosure Statement, Terms of Use, Privacy 

Policy, and Membership Agreement.

(b) In order to become a Trading Member, an applicant who is an 

individual must complete and submit the Nadex on-line membership 

application, provide Nadex with any other information Nadex may 

request, and fund its Nadex account by making a deposit of funds 

belonging to the individual applicant from the individual applicant’s 

account at a US Financial Institution, or as otherwise provided for in 

subsection (a)(i)(2) of this Rule, to the appropriate segregated Cleared 
14

Swap Proprietary Account at Nadex’s settlement bank. An applicant 

who is an Entity must complete an Account Certification, Membership 

Agreement, and W-9, which collectively shall constitute the 

membership application, provide Nadex with any other information 

Nadex may request, and fund its Nadex account by making a deposit of 

funds belonging to the entity applicant from the entity applicant’s 

account at a Financial Institution to the appropriate segregated Cleared 

Swap Proprietary Account at Nadex’s settlement bank. All funds 

deposited by Trading Members shall constitute “Member Property” in 

accordance with CFTC Regulations.

(c) Submission of a membership application to Nadex constitutes the 

applicant’s agreement to be bound by these Rules and other policies of 

Nadex.

(d) If an application is approved by Nadex and the Nadex settlement bank 

confirms to Nadex that the applicant has made a successful initial 

deposit in accordance with paragraph (b) of this Rule, the applicant will 

be a Trading Member of Nadex and will have the following privileges, 

which Nadex may revoke, amend, or expand in accordance with, or by 

amending, these Rules:

(i) to maintain a Nadex account;

(ii) to buy Contracts on the Market using the funds in its Nadex account;

(iii) to sell Contracts on the Market using the funds in its Nadex 

account;

(iv) to view “real-time” the same best bids to buy and offers to 

sell the Contracts traded on the Market as are available to all other 

Members;

(v)to view the current trading volume and open interest for the 

Contracts traded on the Market; and

(vi) to view all non-secure parts of the Nadex website, including 

these Rules, and descriptions of Contracts traded on the Market as 

well as all secure parts of the Nadex website outlined above in Rule 

3.1(d)(i) – (vi).

(e) Nadex may in its sole discretion approve, deny, or condition any 

Member application as Nadex deems necessary or appropriate.
15

(f) A Trading Member that is an individual, may not maintain and/or trade 

more than one Nadex account. No Authorized Trader(s), nor any 

officer, director, member, manager, owner, or indirect owner, of an 

Entity Trading Member may maintain a separate Nadex account and/or 

trade any Nadex account other than that Entity’s account.

RULE 3.2 - 12.24 [UNCHANGED]

RULE 12. 25 ETHER CRYPTOCURRENCY “TOUCH BRACKET” VARIABLE 

PAYOUT CONTRACTS

(a) SCOPE – These Rules shall apply to the Class of Contracts referred to as the 

Ether Cryptocurrency (“Ether”) Touch Bracket Variable Payout Contracts, referred to as a 

‘Touch Bracket”, issued by Nadex.

(b) UNDERLYING – The Underlying for this Class of Contracts is the spot 

Ether cryptocurrency reported in the ICE® Cryptocurrency Data3, aggregated by 

Blockstream® Corporation4and distributed by ICE Data® Connectivity and Feeds, Inc.5, 

herein referred to as “IDCF ETH”, quoted in US dollars.

(c) SOURCE AGENCY – The Source Agency is Nadex.

(d) TYPE – The Type of Contract is a Variable Payout Contract.

(e) PAYOUT CRITERION – The Payout Criterion for each Contract will be set 

by Nadex at the time the Variable Payout Contracts are initially issued. For the Ether Touch 

Brackets, the Payout Criteria for the Contracts will be set as follows: 

3

ICE® is a registered mark of IntercontinentalExchange, Inc. (“ICE”). Nadex is not 

affiliated with ICE or ICE Data Connectivity and Feeds, Inc., and the Ether Cryptocurrency 

“Touch Bracket” Variable Payout Contracts are not sponsored, endorsed, sold or promoted 

by ICE or ICE Data Connectivity and Feeds, Inc. in any way.

4 Blockstream® is a registered mark of Blockstream Corporation (“Blockstream”). Nadex is 

not affiliated with Blockstream and the Ether Cryptocurrency “Touch Bracket” Variable 

Payout Contracts are not sponsored, endorsed, sold or promoted by Blockstream.

5

ICE® is a registered mark of IntercontinentalExchange, Inc. (“ICE”) and ICE Data® is a 

registered mark of Intercontinental Exchange Holdings, Inc (“ICE Holdings”). Nadex is not 

affiliated with ICE, ICE Holdings, or ICE Data Connectivity and Feeds, Inc., and the Ether 

Cryptocurrency “Touch Bracket” Variable Payout Contracts are not sponsored, endorsed, 

sold or promoted by ICE, ICE Holdings, or ICE Data Connectivity and Feeds, Inc. in any 

way.
16

(i) WEEKLY ETHER TOUCH BRACKET VARIABLE PAYOUT 

CONTRACTS, Expiration is the earlier of (a) 4:15PM ET on the Last Trade Day of the 

Contract listing, or (b) when the Ether Index Value is equal to or greater than the Ceiling, or 

equal to or less than the Floor. Nadex shall list a set of four (4) Touch Bracket Variable 

Payout Contracts, each referred to as a ‘Touch Bracket’, that open at 6:00PM ET on the first 

Trade Day of the week, with overlapping ranges, which conform to the Payout Criteria listed 

below.

(1) CONTRACT 1: The Ceiling shall be X + 20080; The Floor shall 

be X - 5020.

(2) CONTRACT 2: The Ceiling shall be X + 15060; The Floor shall 

be X – 10040.

(3) CONTRACT 3: The Ceiling shall be X + 10040; The Floor shall 

be X - 15060.

(4) CONTRACT 4: The Ceiling shall be X + 5020; The Floor shall 

be X – 20080.

(5) DOLLAR MULTIPLIER – The Dollar Multiplier shall be 12.50.

(6) In each case, “X” equals the last IDCF ETH value, as reported by 

the Source Agency, rounded to the nearest 1.

(ii) Upon the early Expiration of a Touch Bracket, Nadex may list a new 

Touch Bracket with a Ceiling of X + 20080 (or 5020) and a Floor of X – 5020 (or 20080) 

where X equals the Ceiling (or Floor) of the Touch Bracket that expired early. The newly 

listed Touch Bracket will have the same Last Trade Day as originally established for the 

expired Touch Bracket and the same Dollar Multiplier as the expired Touch Bracket. 

(f) MINIMUM TICK –The Minimum Tick size for the Ether Touch Bracket 

Variable Payout Contracts shall be 1.

(g) POSITION LIMIT –The Position Limit for the Ether Touch Bracket Variable 

Payout Contracts shall be 250 Contracts.

(h) MARKET MAKER ALTERNATIVE POSITION LIMIT – The Position 

Limit for the Ether Touch Bracket Variable Payout Contracts for contracted Market Makers 

shall be 250,000 Contracts per strike level.

(i) LAST TRADING DATE – The Last Trading Date in a Series is the same date 

as the Settlement Date.
17

(j) SETTLEMENT DATE – The Settlement Date of the Contract shall be the 

same date as the Expiration Date. 

(k) EXPIRATION DATE – The Expiration Date of the Contract shall be the date 

on which the Ether Touch Bracket Expiration Value is released by the Source Agency.

(l) SETTLEMENT VALUE – The Settlement Value is the amount paid to the 

holder of either a Short or Long Variable Payout Contract on Settlement Date. The 

Settlement Value of a Variable Payout Contract is determined as described in the definition 

for Long and Short Variable Payout Contracts.

(m) ETHER INDEX VALUE – The Source Agency shall calculate and produce 

a Ether Index Value once each second throughout the life of the Ether Touch Bracket 

Contracts. That is, each second the Source Agency will calculate a Ether Index Value by 

taking by taking all IDCF ETH midpoints between the bid/ask spread occurring in the ten 

(10) seconds leading up to the Calculation Time, provided at least twenty-five (25) midpoints 

between the bid/ask spread are captured during the sixty (60) second period, removing the 

highest twenty (20) percent of IDCF ETH midpoints between the bid/ask spread and the 

lowest twenty (20) percent of IDCF ETH midpoints between the bid/ask spread from the 

data set6, and using the remaining IDCF ETH midpoints between the bid/ask spread to 

calculate the Ether Index Value for that second. The calculation used is a simple average of 

the remaining IDCF ETH midpoints between the bid/ask spread in the data set, rounded to 

one decimal point past the precision of the Underlying market. In the event the time it takes 

to collect at least twenty-five (25) IDCF ETH midpoints between the bid/ask spread exceeds 

the sixty (60) second period, the Ether Index Value will be calculated by the Source Agency 

by taking the last twenty-five (25) IDCF ETH midpoints between the bid/ask spread just 

prior to the Calculation Time, removing the highest five (5) IDCF ETH midpoints between 

the bid/ask spread and the lowest five (5) IDCF ETH midpoints between the bid/ask spread, 

and using the remaining fifteen (15) IDCF ETH midpoints between the bid/ask spread to 

calculate the Ether Index Value. The calculation used is a simple average of all fifteen (15) 

IDCF ETH midpoints between the bid/ask spread, rounded to one decimal point past the 

precision of the Underlying market.

6

If 20% of the data set would result in a non-integer number of midpoints between the 

bid/ask spread, the number of midpoints between the bid/ask spread to be removed from the 

set will be rounded down. For example, if the number of midpoints between the bid/ask 

spread collected during the last 10 seconds prior to the close of trading was 31, 20% of the 

data set would be 6.2 midpoints between the bid/ask spread. As 6.2 is a non-integer number, 

the value will be rounded down, and the 6 highest and 6 lowest midpoints between the 

bid/ask spread will be removed from the data set.
18

(n) EXPIRATION VALUE – The Expiration Value is the Ether Index Value 

released by the Source Agency at Expiration on the Expiration Date. 

(o) CONTINGENCIES – If no level is actually announced on the Expiration 

Date due to a delay, postponement or otherwise in such release announcement by the Source 

Agency, the Settlement Date will be delayed until the Underlying number is released for that 

Series.

RULES 12.26 – 12.92 [UNCHANGED]

End of Rulebook.