HEDGE
Street

August 2, 2006

'
VIA EMAIL: secretary@cftc.gov sd "
Ms. Eileen A. Donovan, Acting Secretary a =
Secretary of the Commission Bou
Commodity Futures Trading Commission > SO

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

RE: Rule Certification: HedgeStreet® changes the Underlying Gold
Futures Contract Delivery Month for all Gold Binary and Variable
Contracts — Submission pursuant to Commission Regulation §40.6(a)

Dear 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 change the Gold Futures Contract
delivery month used to calculate the Underlying for both the Gold Variable and
Gold Binary Contracts from October 2006 to December 2006 as defined in
HedgeStreet Rule 12.35(b) and Rule 12.66(b) respectively.

Currently, all Gold Binary and Gold Variable Contracts trading on HedgeStreet use
a sampling of prices from the October 2006 Gold Futures Contract (“GFC") traded
on the COMEX Division of the New York Mercantile Exchange (“NYMEX®’)', in
order to calculate the Underlying for such HedgeStreet Gold Contracts in
accordance with HedgeStreet Rules. Due to an unexpected decrease in volume of
the October 2006 GFC, HedgeStreet will commence calculating the Underlying by
applying its proprietary algorithm’ using prices’ from the December 2006 GFC
delivery month instead of the October 2006 GFC delivery month pursuant to the
following schedule:

' NYMEX“ is a registered service mark of the New York Mercantile Exchange, Inc. HedgeStreet, Inc. is not
affiliated with the New York Mercantile Exchange, Inc. and neither the New York Mercantile Exchange, nor its
affiliates, sponsor or endorse HedgeStreet, Inc. in any way.

? The proprietary algorithm used to calculate the Underlying for the Gold Contracts is the same methodology
originally certified to the Commission on January 4, 2005.

3 The term “Prices” does not include any settlement prices calculated or issued by NYMEX.

1825 S. Grant Street
Suite 500
San Mateo, CA 94402

Tel: 650.638.3500
www.hedgestreet.com Fax: 650.638.3501



HEDGE
Street

Daily Gold Binary Contracts - HedgeStreet will change from the October 2006
GFC to the December 2006 GFC on Thursday, August 3, 2006. All Daily Gold
Binary Contracts have an Expiration Date of Wednesday, August 2, 2006.
Therefore, there will be no open interest in any Daily Gold Binary Contracts that
currently have an Underlying of the October 2006 GFC at the close of business on
Wednesday, August 2, 2006.

Weekly Gold Binary and Variable Contracts - HedgeStreet will change from the
October 2006 GFC to the December 2006 GFC on Monday, August 7, 2006. All
Weekly Gold Binary and Gold Variable Contracts have an Expiration Date of
Friday, August 4, 2006. Therefore, there will be no open interest in any Weekly
Gold or Binary Contracts that currently have an Underlying of the October 2006
GFC at the close of business on Friday, August 4, 2006.

In summary, HedgeStreet intends to implement these rule amendments for the Daily
Gold Binary Contracts on Thursday, August 3, 2006 and for the Weekly Binary and
Variable contracts on Monday, August 7, 2006.

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
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