LMX Labs, LLC d/b/a Coinbase Derivatives

November 10, 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: Modification to Rule 601 (“Block Trades”)

and Establishment of Block Trade Minimum Thresholds and Reporting Times

Coinbase Derivatives Submission #2023-12

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 modifications to Exchange Rule 601 (“Block Trades”). The purpose of the

modification is to state the products that will be eligible for block trades. Additionally, the

Exchange is establishing block trade minimum thresholds and reporting times for such

block-eligible contracts. The modifications, thresholds, and reporting times become effective

December 1, 2023.

The modification to Rule 601 is set forth in Appendix A and the block trade minimum thresholds

and reporting times are set forth in Appendix B, both attached hereto.

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 modifications:

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

Disruption

All trading on the Exchange, including those conducted by affiliated participants or otherwise, 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.

1
Additionally, all trading on the Exchange, regardless of affiliation to the Exchange, 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 7 - Availability of General Information

The Exchange shall continue to publish on its website and in its Rulebook the modification to

Rule 601. Additionally, information on the modification and the establishment of block trade

minimum thresholds and reporting times will be communicated to market participants via a

notice which will be made available on the Exchange’s website.

Core Principle 9 - Execution of Transactions

A DCM may authorize transactions that are executed away from the DCM’s trading system for

bona fide business purposes. The actions certified herein serve to state the products that will be

eligible for block trades and establish block trade minimum thresholds and reporting times for

such block-eligible contracts.

Core Principle 12 - Protection of Markets and Market Participants

Chapters 4 and 5 of the Rulebook require all market participants, affiliated or otherwise, 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 on the Exchange will be subject to monitoring and surveillance by the

Market Regulation Department and enforced by the Exchange regardless of affiliation with the

Exchange.

Certification

The Exchange is not aware of any substantive opposing views to Rule 601 or the establishment

of block trade minimum thresholds and reporting times for such block-eligible contracts. The

Exchange certifies that Rule 601 and the establishment of block trade minimum thresholds and

reporting times for such block-eligible contracts 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

Appendix B

2
APPENDIX A

Rule 601. “Block Trades”

(additions underlined; deletions stricken-through)

RULE 601. Block Trades

(b) Products designated for Block Trades.

None(1) Bitcoin Futures (BTI Contract)

(2) Ether Futures (ETI Contract)

3
APPENDIX B

Block Thresholds and Reporting Times

Contract Title Product Trading Code Block Trade Minimum

Quantity Threshold Level

Reporting Time

(Minutes)

Bitcoin Futures BTI 25 15

Ether Futures ETI 25 15

4