KalshiEX LLC

Attachments:

Appendix A - Contract Terms and Conditions

Appendix B (Confidential) - Further Considerations
Appendix C (Confidential) - Source Agency

Appendix D (Confidential) - Compliance with Core Principles

KalshiEX LLC


KalshiEX LLC

Minimum Tick: The Minimum Tick size for the referred Contract shall be $0.01.

Position Limit: The Position Limit for the $1 referred Contract shall be $25,000 per Member.
Last Trading Date: The Last Trading Date of the Contract will be the sooner of the first 10:00
AM ET following <date> (whereupon the Last Trading Time will be 10:00 AM ET) or <date>
(whereupon the Last Trading Time will be 11:59 PM ET).

Settlement Date: The Settlement Date of the Contract shall be no later than the day after the
Expiration Date, unless the Market Outcome is under review pursuant to Rule 7.1.

Expiration Date: The Expiration Date of the Contract shall be the sooner of the date of the first
10:00 AM ET following the occurrence of an event that is encompassed in the Payout Criterion
or the date of the first 10:00 AM ET following <date>.

Expiration time: The Expiration time of the Contract shall be 10:00 AM ET.

Settlement Value: The Settlement Value for this Contract is $1.00.

Expiration Value: The Expiration Value is the value of the Underlying as documented by the
Source Agency on the Expiration Date at the Expiration time.

Contingencies: Before Settlement, Kalshi may, at its sole discretion, initiate the Market
Outcome Review Process pursuant to Rule 6.3(c) of the Rulebook.

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KalshiEX LLC

CERTIFICATIONS PURSUANT TO SECTION Sc OF THE COMMODITY EXCHANGE
ACT, 7 U.S.C. § 7A-2 AND COMMODITY FUTURES TRADING COMMISSION RULE
40.2, 17 C.ER. § 40.2

Based on the above analysis, the Exchange certifies that:
(4 The Contract complies with the Act and Commission regulations thereunder.
4 This submission (other than those appendices for which confidential treatment has been
requested) has been concurrently posted on the Exchange’s website at
https://kalshi.com/regulatory/filings.

Should you have any questions concerning the above, please contact the exchange at
ProductFilings@kalshi.com.

By: Xavier Sottile
Title: Head of Markets
Date: November 20, 2023

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KalshiEX LLC

APPENDIX A —- CONTRACT TERMS AND CONDITIONS

Official Product Name: Will Sam Altman start a new AI organization by <date>?
Rulebook: ALTMAN

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KalshiEX LLC

November 20, 2023

SUBMITTED VIA CFTC PORTAL
Secretary of the Commission

Office of the Secretariat

U.S. Commodity Futures Trading Commission
Three Lafayette Centre

1155 21st Street, N.W.

Washington, D.C. 20581

Re: KalshiEX LLC — CFTC Regulation 40.2(a) Notification Regarding the Initial Listing
of the “Will Sam Altman start a new AI organization by <date>?” Contract

Dear Sir or Madam,

Pursuant to Section 5c(c) of the Commodity Exchange Act and Section 40.2(a) of the regulations of the
Commodity Futures Trading Commission, KalshiEX LLC (Kalshi) hereby notifies the Commission that
it is self-certifying the “Will Sam Altman start a new AI organization by <date>?” contract (Contract).
The Exchange intends to list the contract on a custom basis. The contract will be initially listed after
close-of-business on November 20, 2023; it is listed as November 21, 2023 because of limitations of the
Commission's online submission portal. The Contract’s terms and conditions (Appendix A) includes the
following strike conditions:
e <date> (the target date)

Along with this letter, Kalshi submits the following documents:

A concise explanation and analysis of the Contract;
Certification;

Appendix A with the Contract’s Terms and Conditions;
Confidential Appendices with further information; and
A request for FOIA confidential treatment.

If you have any questions, please do not hesitate to contact me.

Sincerely,

Xavier Sottile

Head of Markets
KalshiEX LLC
xsottile@kalshi.com

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KalshiEX LLC

ALTMAN

Scope: These rules shall apply to this contract.

Underlying: The Underlying for this Contract is statements from Sam Altman, a co-founder of
OpenAI and entrepreneur. This would include statements from his Twitter account, his blog, as
well as publicly recorded statements by him (e.g. a public interview). Revisions to the
Underlying made after Expiration will not be accounted for in determining the Expiration Value.

Type: The type of Contract is an Event Contract.

Issuance: After the initial Contract, Contract iterations will be listed on an as-needed basis at the
discretion of the Exchange and corresponding to the risk management needs of Members.

<date>: <date> refers to a calendar date specified by Kalshi. Kalshi may list iterations of the
Contract corresponding to different statistical periods of <date>.

Payout Criterion: The Payout Criterion for the Contract encompasses the Expiration Values that
Sam Altman has founded a new organization in the AI sector between Issuance and <date>.

- The organization must be in Al-related work. A new venture in AI specialized computer
chips would satisfy the Payout Criterion.

- The announcement must be clear that (i) an organization will be or has been formed, and
(ii) that organization is doing Al-related work. For example, Altman tweeting ‘new thing
coming soon’ would not be sufficient to satisfy the Payout Criterion. Similarly, and
announcement that he is considering forming such an organization would not be
sufficient to satisfy the Payout Criterion.

- Involvement in expansions or rebranding of existing projects, companies, or initiatives
where Sam Altman is already involved (including his Microsoft role, which was
announced on November 20, 2023) does not qualify. Similarly, Sam Altman taking on
advisory roles or board memberships in new AI companies does not meet the criteria.
Altman becoming CEO of an already existing AI organization would not satisfy the
Payout Criterion.

- Nonprofits are encompassed by the Payout Criterion.

The announcement must remain available at the Expiration Time on the Expiration Date. If an
announcement that would be included in the Payout Criterion is either retracted or a subsequent
announcement is made prior to the Contract’s Expiration Time on the Expiration Date that
Altman has decided to not form the organization, that original announcement is not included in
the Payout Criterion.

KalshiEX LLC


KalshiEX LLC

KalshiEX LLC

Official Product Name: Will Sam Altman start a new AI organization by <date>?
Rulebook: ALTMAN

Kalshi Contract Category: Science/Technology

New Altman organization

November 20, 2023

CONCISE EXPLANATION AND ANALYSIS OF THE PRODUCT AND ITS

COMPLIANCE WITH APPLICABLE PROVISIONS OF THE ACT, INCLUDING CORE

PRINCIPLES AND THE COMMISSION'S REGULATIONS THEREUNDER

Pursuant to Commission Rule 40.2(a)(3)(v), the following is a concise explanation and analysis
of the product and its compliance with the Act, including the relevant Core Principles, and the
Commission's regulations thereunder.

I.

Introduction

The “Will Sam Altman start a new AI organization by <date>?” Contract is a contract
relating to Sam Altman’s new professional plans. After careful analysis, Kalshi (hereafter
referred to as “Exchange’”’) has determined that the Contract complies with its vetting
framework.

Sam Altman is the co-founder and former CEO of OpenAI. He was fired on November
17, 2023. His success in the sector has placed many eyes on his next project.

Further information about the Contract, including an analysis of its risk mitigation and
price basing utility, as well as additional considerations related to the Contract, is
included in Confidential Appendices B, C, and D.

Pursuant to Section Sc(c) of the Act and CFTC Regulations 40.2(a), the Exchange hereby
certifies that the listing of the Contract complies with the Act and Commission
regulations under the Act.

General Contract Terms and Conditions: The Contract operates similar to other event
contracts that the Exchange lists for trading. The minimum price fluctuation is $0.01 (one
cent). Price bands will apply so that Contracts may only be listed at values of at least
$0.01 and at most $0.99. Further, the Contract is sized with a one-dollar notional value
and has a minimum price fluctuation of $0.01 to enable Members to match the size of the
contracts purchased to their economic risks. The Exchange has further imposed position
limits (defined as maximum loss exposure) of $25,000 USD on the Contract. As outlined
in Rule 5.12 of the Rulebook, trading shall be available at all times outside of any

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KalshiEX LLC

maintenance windows, which will be announced in advance by the Exchange. Members
will be charged fees in accordance with Rule 3.6 of the Rulebook. Fees are charged in
such amounts as may be revised from time to time to be reflected on the Exchange’s
Website. A new Source Agency can be added via a Part 40 amendment. All instructions
on how to access the Underlying are non-binding and are provided for convenience only
and are not part of the binding Terms and Conditions of the Contract. They may be
clarified at any time. Furthermore, the Contract’s payout structure is characterized by the
payment of an absolute amount to the holder of one side of the option and no payment to
the counterparty. During the time that trading on the Contract is open, Members are able
to adjust their positions and trade freely. After trading on the Contract has closed, the
Expiration Value and Market Outcome are determined. The market is then settled by the
Exchange, and the long position holders and short position holders are paid according to
the Market Outcome. In this case, “long position holders” refers to Members who
purchased the “Yes” side of the Contract and “short position holders” refers to Members
who purchased the “No” side of the Contract. If the Market Outcome is “Yes,” meaning
that Sam Altman has announced a new AI company by <date>, then the long position
holders are paid an absolute amount proportional to the size of their position and the short
position holders receive no payment. If the Market Outcome is “No,” then the short
position holders are paid an absolute amount proportional to the size of their position and
the long position holders receive no payment. Specification of the circumstances that
would trigger a Market Outcome of “Yes” are included below in the section titled
“Payout Criterion” in Appendix A.

KalshiEX LLC