152 Madison Avenue

21st Floor

New York, NY 10016

e: ian@ledgerx.com

o: +1 917-677-7598

w: ledgerx.com

September 21, 2017

FOIA CONFIDENTIAL TREATMENT REQUEST

Pursuant to 17 C.F.R. §§ 145.5 and 145.9

BY ELECTRONIC MAIL (FOIAsubmissions@cftc.gov)

Assistant Secretary of the Commission for FOI,

Privacy and Sunshine Acts Compliance

Commodity Futures Trading Commission

Three Lafayette Centre

1155 21st Street, N.W.

Washington, D.C. 20036

Re: Petition for Confidential Treatment

Dear Sir or Madam:

LedgerX LLC (“LedgerX”) has on this date provided the documents described in Appendix A to 

this letter (the “Confidential Submission”) through the CFTC Portal.

In accordance with the provisions of Commission Regulations 145.5 and 145.9, we hereby request 

confidential treatment of the Confidential Submission. Confidential treatment is requested, inter 

alia, on the grounds that the Confidential Submission contains data and information which would 

separately disclose business transactions and trade secrets that may not be disclosed to third 

parties, as provided in Section 8(a) of the Commodity Exchange Act and Commission Regulation 

145.5(c)(1). Confidential treatment additionally is requested on the grounds that the Confidential 

Submission is exempt from disclosure under paragraph (b)(4) of the Freedom of Information Act 

(“FOIA”) and Commission Regulations 145.5(d) and 145.9(d)(1)(ii) because it contains 

commercial and financial information that is confidential and would be of material assistance to 

competitors of LedgerX.

In accordance with the provisions of paragraph (d)(5) of Regulation 145.9, we request that the 

Confidential Submission be afforded confidential treatment in perpetuity.

We understand that if the Commission receives a FOIA request for the Confidential Submission, 

we will be notified of such request in accordance with the Commission’s regulations and be asked 

to submit, within ten business days, a detailed written justification for confidential treatment of the 

Confidential Submission. See Commission Regulation 149.5(e)(1); see also Executive Order 

12600, 52 Fed. Reg. 23781 (June 23, 1987) (detailing pre-disclosure notification procedures under 

FOIA). In such event, we request that Commission staff telephone or email the undersigned rather 

than rely upon United States mail for such notice.
Assistant Secretary of the Commission for FOI,

Privacy and Sunshine Acts Compliance

Page 2

If the Commission or its staff transmits any of the Confidential Submission to another federal 

agency, we request that you forward a copy of this letter to any such agency with the Confidential 

Submission and further request that you advise any such agency that LedgerX has requested that 

this material be accorded confidential treatment.

The requests set forth in the preceding paragraphs also apply to any memoranda, notes, transcripts 

or other writings of any sort whatsoever that are made by, or at the request of, any employee of 

the Commission (or any other federal agency) and which (1) incorporate, include or relate to any 

aspect of the Confidential Submission; or (2) refer to any conference, meeting, or telephone 

conversation between LedgerX, its current or former employees, representatives, agents, auditors 

or counsel on the one hand and employees of the Commission (or any other government agency) 

on the other, relating to the Confidential Submission. 

* * * *

Any questions regarding this request for Confidential Treatment, as well as any notices pursuant 

to Commission Regulation 145.9(e), should be directed to the attention of the undersigned at the 

telephone number and address set forth herein.

Sincerely,

Ian J. Darrow

General Counsel

Encl. (Appendix A)
APPENDIX A

to September 21, 2017 Confidential Treatment Request

from Ian J. Darrow, LedgerX LLC

The Confidential Submission referenced in the letter to which this Appendix A is attached consists 

of this Appendix A and a redlined version of LedgerX’s Operations Manual.