AQUA-INDEX EXCHANGE, LLC 

216 West Jackson Blvd 

Suite 400 

Chicago, IL 60606 

Via E-mail

March 11, 2016 

Assistant Secretary of the Commission for FOI Matters, 

Privacy and Sunshine Acts Compliance, 

Commodity Futures Trading Commission, 

Three Lafayette Centre, 

1155 21st Street, N.W., 

Washington, D.C. 20581 

FOIAsubmissions@cftc.gov

Re: FOIA Confidential Treatment Request: Petition Pursuant to Regulation 145.9(d) 

To Whom It May Concern: 

On this date, AQUA-INDEX EXCHANGE, LLC (“AIX”) submitted by e-mail 

to Christopher J. Kirkpatrick, Secretary of the Commodity Futures Trading Commission 

(the “Commission”), the pdf file listed below, which constitutes an amendment to AIX’s 

application to be designated as a contract market pursuant to Section 5 of the 

Commodity Exchange Act, as amended (the “CEA”), and Part 38 of the regulations 

promulgated by the Commission: 

1. DCM_Application_Amendment_Privileged_and_Confidential.pdf.

By this petition, AIX requests confidential treatment of the following materials contained 

in the above-mentioned pdf file, a copy of which is attached to the e-mail by which this 

petition is being submitted. Each page of following materials is marked with the 

statement “Confidential Treatment Requested by AQUA-INDEX EXCHANGE, LLC” 

pursuant to Section 145.9(d) of the Commission’s regulations promulgated under the 

CEA. 

1. Exhibit B (officer and director information), including appended

Exhibits B-1 through B-2;

2. Exhibit C (fitness standards; composition of board);

3. Exhibit E (personnel qualifications);

4. Exhibit F (staffing requirements);

Pursuant to Sections 8(a) of the CEA, and Commission Regulation 

§ 145.9(d), AIX requests confidential treatment of the Confidential Materials under the

Freedom of Information Act on the grounds that disclosure of such materials would

reveal trade secrets and/or confidential commercial information of AIX. The Confidential

Materials are proprietary to AIX and contain highly sensitive and confidential business

and technology information. In addition to violating AIX’s proprietary rights, the

disclosure of the Confidential Materials would grant competitors an unfair competitive
advantage and/or compromise the competitive advantages possessed by AIX. 

Accordingly, we ask that you take appropriate steps to keep the Confidential Materials 

confidential and that you restrict the re-distribution of the Confidential Materials.

Pursuant to Commission Regulation § 145.9(d)(5), AIX hereby requests 

that the Confidential Materials be afforded confidential treatment in perpetuity.

AIX requests that the Commission notify the undersigned immediately 

after receiving any Freedom of Information Act request, any court order, subpoena, or 

summons seeking to access the Confidential Materials in whole or in part. AIX further 

requests notification (through the undersigned) in the event that the Commission intends 

to disclose the Confidential Materials in whole or in part. AIX does not waive its 

notification rights under Section 8(f) of the CEA with respect to any subpoena or 

summons with respect to the Confidential Materials in whole or in part.
Please contact Bob Gaffney or Kenneth M. Raisler using the infonnation 

below if you have any questions regarding this request for confidential treatment. 

(Enclosures) 

Robert Gaffney 

Phone: 

Kenneth M. Raisler 

Sullivan 8, Cromwell LLP 

125 Broad street 

New York. NY 10004 

Phone: (212) 558-4675 

cc: Christopher J. Kirkpatrick 

(Commodity Futures Trading Commission) 

Yaacov Shirazi 

Gerald L. Fishman 

(AQUA-INDEX EXCHANGE, LLC) 

Kenneth M. RaislElf 

David J_ Gilberg 

(Sullivan & Cromwell LLP) 

Sincerely, 

Robert Gaffney 

Chief Executive Officer 

AQUA-INDEX EXCHANGE, LLC 

(917) 603-2892