“Will CDNA/Nadex/OG.com’s event contract notional traded volume exceed $2 billion in November 2026?” Event Contract

ProphetX LLC · received by the CFTC 23 October 2026 · the filing (PDF)

Summary

Warrant Check read 4 operative provisions in this filing. Across them, 16 of 24 checks are present, 4 partial and 4 absent. 2 provisions have every check present. 1 statement the exchange makes to the CFTC about the filing itself (such as that it complies with the Act) is not contract terms and is left out. 1 rule on who may trade is not a settlement term and is left out.

16 present4 partial4 absent

What the wording addresses

Settlement Criteria (Yes/No determination) — every check present.
“Resolves to "Yes" if the Reference Volume exceeds”
Change in Publication - void/return: Comprehensive Coverage, Relevant Timeline.
“all orders on the Contract are void and collateral is returned”
Absence of Data - void/return: Comprehensive Coverage, Relevant Timeline.
“ProphetX cannot reasonably determine the outcome”
Corrections and Restatements finality — every check present.
“Corrections published after the Determination Cutoff ... do not affect settlement”

What the wording leaves open

Change in Publication - void/return “all orders on the Contract are void and collateral is returned”
- Independent Verification — Partial: Non-availability of a publication is objectively checkable, but 'unequivocally determined' is the Exchange's own assessment rather than a named third-party proof.
- Suitable Method — Partial: Checking whether a publication exists is capable of being established; whether the outcome is 'unequivocal' is not a procedure with defined precision.
- Defined Benchmark — Partial: No publication/no alternative is a clear trigger, but 'unequivocally determined' is an undefined, elastic threshold.
- Conclusive Link — Partial: Given the loosely defined 'unequivocally determined' standard, meeting it plausibly but not certainly establishes the voidance claim.
What would close it: Define 'unequivocally determined' with an objective sufficiency test (e.g., a named alternative source or residual-data threshold).
Absence of Data - void/return “ProphetX cannot reasonably determine the outcome”
- Independent Verification — Absent: Trigger rests on ProphetX's own reasonable-determination judgment, not a named receivable third-party proof.
- Suitable Method — Absent: 'Cannot reasonably determine' is an unstructured discretionary judgment, not a checkable procedure capable of establishing the claim at the asserted certainty.
- Defined Benchmark — Absent: No threshold or defined test for 'reasonably determine' is given.
- Conclusive Link — Absent: no named standard - entailment cannot be assessed
What would close it: Specify objective criteria or a named fallback data source defining when the outcome is 'undeterminable.'

Every provision read

Settlement Criteria (Yes/No determination)

“Resolves to "Yes" if the Reference Volume exceeds”

Determination: The Reference Volume, computed from Nadex's published fully-collateralized trading data for the Reference Period, exceeds $2,000,000,000 · Consequence: Contract settles "Yes" (payout $1.00 to Yes holders) or "No" (No holders paid nothing)

Present Independent Verification. Evidence is Nadex's publicly posted Daily Bulletin/Time and Sales reports, a neutral third-party published dataset, not any party's opinion.

Present Suitable Method. A fixed, non-discretionary summation formula over a named published Volume column can establish the exact numeric claim asserted.

Present Defined Benchmark. Explicit numeric threshold of $2,000,000,000, stated to the dollar with no tie outcome.

Present Conclusive Link. Reference Volume is defined as exactly the computed figure, so exceeding/not exceeding the threshold directly constitutes the Yes/No outcome.

Present Comprehensive Coverage. Defined coverage is every fully collateralized transaction executed on Nadex across all access channels, matching the claim's scope of 'Nadex's notional traded volume.'

Present Relevant Timeline. Reference Period (Nov 1-30, 2026 trade dates) matches the claim period 'November 2026.'

Change in Publication - void/return

“all orders on the Contract are void and collateral is returned”

Determination: Nadex has stopped/materially changed/restricted publication, no alternative means is available, and the Market Outcome has not been unequivocally determined · Consequence: All orders voided and collateral returned

Partial Independent Verification. Non-availability of a publication is objectively checkable, but 'unequivocally determined' is the Exchange's own assessment rather than a named third-party proof.

Partial Suitable Method. Checking whether a publication exists is capable of being established; whether the outcome is 'unequivocal' is not a procedure with defined precision.

Partial Defined Benchmark. No publication/no alternative is a clear trigger, but 'unequivocally determined' is an undefined, elastic threshold.

Partial Conclusive Link. Given the loosely defined 'unequivocally determined' standard, meeting it plausibly but not certainly establishes the voidance claim.

Present Comprehensive Coverage. Applies to the same Nadex fully-collateralized data set covering the whole Reference Period.

Present Relevant Timeline. Triggered relative to the Determination Cutoff/Reference Period, matching the obligation's timeframe.

Absence of Data - void/return

“ProphetX cannot reasonably determine the outcome”

Determination: ProphetX cannot reasonably determine the outcome of the Contract from any listed or alternative source · Consequence: All orders on the Contract voided and collateral returned

Absent Independent Verification. Trigger rests on ProphetX's own reasonable-determination judgment, not a named receivable third-party proof.

Absent Suitable Method. 'Cannot reasonably determine' is an unstructured discretionary judgment, not a checkable procedure capable of establishing the claim at the asserted certainty.

Absent Defined Benchmark. No threshold or defined test for 'reasonably determine' is given.

Absent Conclusive Link. no named standard - entailment cannot be assessed

Present Comprehensive Coverage. Covers the same Nadex fully-collateralized data population as the main claim.

Present Relevant Timeline. Tied to the same Reference Period/settlement timing as the primary obligation.

Corrections and Restatements finality

“Corrections published after the Determination Cutoff ... do not affect settlement”

Determination: A correction or restatement of the Nadex data is published after the Determination Cutoff · Consequence: No effect on settlement; no Contract is resettled

Present Independent Verification. Evidence is the timing of Nadex's own published corrections/restatements, a neutral, receivable fact (publication timestamp).

Present Suitable Method. Comparing a publication timestamp to a fixed cutofftime is a precise, checkable procedure matching the claim's certainty.

Present Defined Benchmark. Determination Cutoffis precisely defined (5:00 p.m. ET, second business day after Reference Period ends).

Present Conclusive Link. A correction published after that fixed time, by definition, falls outside the settlement computation window.

Present Comprehensive Coverage. Applies to the same Nadex fully-collateralized dataset as the primary Reference Volume calculation.

Present Relevant Timeline. The cutoffprecisely delineates the time period the settlement evidence covers.

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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