Gemini Titan, LLC Product Self-Certification under 17 C.F.R. § 40.2(a) for “Will the Dallas Wings win the 2027 WNBA Championship?” Event Contract.

Gemini Titan, LLC · received by the CFTC 21 September 2026 · the filing (PDF)

What the wording addresses

• Championship declaration / main settlement — every check present.
  “officially declared the champion of the 2027 WNBA season”
• Elimination resolves No: Independent Verification, Comprehensive Coverage, Relevant Timeline.
  “eliminated from championship contention prior to the conclusion”
• Withdrawal/forfeiture/disqualification resolves No: Comprehensive Coverage, Relevant Timeline.
  “withdraw, forfeit, or are disqualified from the 2027 WNBA season”
• Postponement/delay keeps contract open: Comprehensive Coverage.
  “postponed, delayed, or extended for any reason, the Contract shall remain open”

What the wording leaves open

• Elimination resolves No “eliminated from championship contention prior to the conclusion”
  • Suitable Method — Partial: Elimination is usually a clear sports event, but the broad phrase 'can no longer be declared champion' leaves some scenarios to interpretation
  • Defined Benchmark — Partial: 'Eliminated from championship contention' is gestured at without a precise bracket/mathematical-elimination rule
  • Conclusive Link — Partial: Meeting the loosely defined elimination concept generally establishes the claim but edge cases are unaddressed
  What would close it: Define 'elimination from championship contention' by reference to official WNBA bracket/elimination rules
• Withdrawal/forfeiture/disqualification resolves No “withdraw, forfeit, or are disqualified from the 2027 WNBA season”
  • Independent Verification — Partial: No source is named for confirming withdrawal/forfeiture/disqualification, unlike the main clause's explicit Source Agency documentation
  • Suitable Method — Partial: No procedure specified for how such an event is confirmed or verified
  • Defined Benchmark — Partial: 'Withdraw', 'forfeit', and 'disqualified' are used without definitions or thresholds
  • Conclusive Link — Partial: Meeting these undefined categories generally indicates the claim, but lack of definition leaves room for dispute
  What would close it: Specify that such events be documented by the Source Agency (or a named authority) and define each triggering term
• Season cancellation discretionary settlement “resolve to the last fair price determined in the sole discretion”
  • Independent Verification — Absent: Settlement value rests on the Exchange's own discretionary judgment, not any external or neutral evidence
  • Suitable Method — Absent: 'Sole discretion' is not a procedure capable of establishing an objective fair price; it is the party's own say-so
  • Defined Benchmark — Absent: 'Last fair price' is undefined, with no methodology, index, or reference market named
  • Conclusive Link — Absent: no named standard - entailment cannot be assessed
  • Comprehensive Coverage — Absent: No defined population or market data set is used to derive the price
  • Relevant Timeline — Absent: No time window specified for determining the 'last fair price'
  What would close it: Define an objective methodology (e.g., volume-weighted average of trades over a stated window) for cancellation settlement
• Postponement/delay keeps contract open “postponed, delayed, or extended for any reason, the Contract shall remain open”
  • Independent Verification — Partial: No source is explicitly named here for confirming postponement/delay/extension, though the Source Agency framework is used elsewhere
  • Suitable Method — Partial: The determination of postponement/delay/extension is not tied to any specific verifiable procedure in this sub-clause
  • Defined Benchmark — Absent: No defined threshold distinguishing postponement, delay, or extension, nor any duration trigger
  • Conclusive Link — Absent: no named standard - entailment cannot be assessed
  • Relevant Timeline — Partial: Contract remains open indefinitely with no outer limit, leaving the covered duration open-ended
  What would close it: Tie the postponement/delay determination to Source Agency reporting and set an outer time limit for remaining open
• Market Outcome Review Process discretion “the Exchange has the right to determine payouts pursuant to Rule 7.1”
  • Independent Verification — Absent: Relies on the Exchange's own discretionary right; the underlying Rule 7.1 process is not supplied in the text
  • Suitable Method — Absent: Without Rule 7.1's content, the procedure's capability to establish the claim cannot be assessed; as stated it is purely discretionary
  • Defined Benchmark — Absent: No standard is given in the supplied text; Rule 7.1's content is absent
  • Conclusive Link — Absent: no named standard - entailment cannot be assessed
  • Comprehensive Coverage — Absent: Scope of the Rule 7.1 review process is not defined in the supplied text
  • Relevant Timeline — Absent: No time period specified for the review or determination process
  • Relies on material referred to but not in the public filing.
  What would close it: Include Rule 7.1's procedural content (standards, evidence, timelines) so the determination can be assessed

Every provision read

Read 31 October 2026 with Warrant Check (instrument 1.0). Labels: Present, Partial, Absent describe whether each check is found in the wording as written.

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