HEDGE
Street
June 19, 2006

VIA EMAIL: secretary@cftc.gov

Ms. Eileen A. Donovan, Acting Secretary €
Secretary of the Commission oF
Commodity Futures Trading Commission co
3 Lafayette Centre

1155 21st Street, N.W.
Washington, D.C. 20581

®
RE: Rule Certification: HedgeStreet Re-lists Weekly Crude Oil Variable Payout Contract:
with Larger Settlement Values — Submission pursuant to Commission Regulation
§40.6(a)

Dear Secretary Webb:

Pursuant to Section Sc(c)(1) of the Commodity Exchange Act, as amended (“Act”), §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 that it intends to re-list Weekly Crude Oil contracts (“Contracts”) as defined in
HedgeStreet Rule 12.36(f(i). In addition, HedgeStreet is increasing the Settlement Value for
such Contracts to $100. As a result of the increase in the Settlement Value amount,
HedgeStreet is amending i) the Payout Criteria for the Contracts; and ii) both the reporting level
and speculative position limits for these Contracts in order to accommodate the larger
Settlement Value. All amendments for these Contracts are defined in Exhibit A. The rule
deletions are stricken out and the amendments and/or additions are underlined.

HedgeStreet intends to implement these rule amendments at the start of business on Tuesday,
June 20, 2006. No substantive opposing views were expressed to HedgeStreet with respect to
these additions.

HedgeStreet hereby certifies that the Contracts and clearing of the Contracts, including all rules
defining the terms and conditions of said Contracts contained herein, complies with the Act, as
amended, and the Commission’s regulations adopted thereunder.

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: Clarissa Manansala — HedgeStreet , Inc.

1825 S. Grant Street
Suite 500
‘San Mateo, CA 94402
Tel: 650.638.3500
www.hedgestreet.com Fax: 650.638.3501


Exhibit A

HEDGE
Street
EXHIBIT A

Amendments to Rule 12.36 only
(The following new Rule additions are underlined and deletions are stricken out)

RULE 12.36 CRUDE OIL VARIABLE PAYOUT CONTRACTS
(a) - (e) [unchanged]

(f) PAYOUT CRITERION — The Payout Criterion for each Contract
will be set by HedgeStreet at the time the Variable Payout Contracts are initially
issued. For the Variable Payout Hedgelet Contract, the Payout Criteria for the
Contracts will be set as follows;

(i) WEEKLY VARIABLE CRUDE OIL CONTRACT

@) DOLLAR MULFPLIER—The Dollar Multiplier shall be.
ded-to-th: + dolar ($100) rted-by-the-S. A
AS aeeeE) ported oy BORECY:

(1) WEEKLY VARIABLE PAYOUT CONTRACT 1

(aa) CAP — The Cap shall be X.

(bb) FLOOR — The Floor shall be X - $10.00.

(cc) DOLLAR MULTIPLIER — The Dollar Multiplier shall be 10.

(2) WEEKLY VARIABLE PAYOUT CONTRACT 2

(aa) CAP — The Cap shall be X + $5.00

(bb) FLOOR ~ The Floor shall be X - $5.00

(cc) DOLLAR MULTIPLIER — The Dollar Multiplier shall be 10.

(3) WEEKLY VARIABLE PAYOUT CONTRACT 3

1825 S. Grant Street

Sulte 500

‘Sen Mateo, CA 94402

Tel: 650.638.3500
www-.hedgestreet.com Fax: 650.638.3501


Exhibit A

HEDGE
Street
(aa) CAP — The Cap shall be X + $10.00

(bb) FLOOR - The Floor shall be X.
(cc) DOLLAR MULTIPLIER — The Dollar Multiplier shall be 10.

(4) In each case, “‘X” equals the last Expiration Value of Crude Oil,
rounded to the nearest five dollars ($490) ($5.00), as reported by the Source
Agency.

(ii) — (v) [unchanged]
(g) [unchanged]

(h) REPORTING LEVEL — The Reporting Level for the Crude Oil
Variable Payout Hedgelets shall be 44,667 12,500 Contracts.

(i) POSITION LIMIT — The Position Limits for Crude Oil Variable
Payout Hedgelets shall be 833,333 250,000 Contracts.

()-(©) [unchanged]

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

1825 S. Grant Street

‘Suite 500

San Mateo, CA 94402

Tel: 650.638.3500
www.hedgestreet.com Fax: 650.638.3501