Will Gemini’s event contract notional traded volume exceed $<N> in <Month>?

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

Summary

Warrant Check read 4 operative provisions in this filing. Across them, 14 of 24 checks are present, 6 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.

14 present6 partial4 absent

What the wording addresses

Settlement Criteria (Yes/No determination) — every check present.
“Resolves to Yes if the Reference Volume exceeds”
Corrections and Restatements finality — every check present.
“Corrections published after the Determination Cutoff ... do not affect settlement”
Change in Publication (void and return collateral): Comprehensive Coverage, Relevant Timeline.
“Market Outcome has not been unequivocally determined, all orders ... are void”

What the wording leaves open

Change in Publication (void and return collateral) “Market Outcome has not been unequivocally determined, all orders ... are void”
- Independent Verification — Partial: Stoppage of publication is objectively observable, but 'materially changes' and 'unequivocally determined' are the Exchange's own characterizations with no named third-party check.
- Suitable Method — Partial: Can detect an outright stoppage, but cannot reliably establish the more elastic 'material change' or 'unequivocal' determination at the certainty the clause implies.
- Defined Benchmark — Partial: Triggering conditions are listed but 'materially changes' and 'unequivocally determined' are undefined, elastic terms.
- Conclusive Link — Partial: Given the elasticity of the standard, satisfying it does not reliably or verifiably establish the claimed state of affairs.
What would close it: Define 'materially changes' and 'unequivocally determined' with objective, checkable criteria or designate an independent arbiter.
Absence of Data (void and return collateral) “ProphetX cannot reasonably determine the outcome ... all orders ... void”
- Independent Verification — Absent: Rests entirely on ProphetX's own satisfaction ('cannot reasonably determine'), with no named independent evidence or third-party check.
- Suitable Method — Absent: 'Reasonably determine' is not a checkable procedure; it is the Exchange's subjective assessment, not a method capable of establishing the claim at any defined certainty.
- Defined Benchmark — Absent: No threshold, test, or criteria are specified for what counts as being unable to 'reasonably determine' the outcome.
- Conclusive Link — Absent: no named standard - entailment cannot be assessed
- Comprehensive Coverage — Partial: Applies to the specific Contract's outcome, but with no defined procedure it is unclear what population of data sources was actually checked.
- Relevant Timeline — Partial: No explicit window is stated for when this assessment occurs relative to the Determination Cutoff.
What would close it: Specify objective conditions (e.g., enumerated source failures) or require independent confirmation before invoking inability to determine the outcome.

Every provision read

Settlement Criteria (Yes/No determination)

“Resolves to Yes if the Reference Volume exceeds”

Determination: the Reference Volume (summed contract counts from Gemini Titan data) exceeds the stated threshold N · Consequence: binary $1.00 payout to the Yes side (or No side if not exceeded)

Present Independent Verification. Evidence is Gemini Titan's published Market Data (and Trade Data/hourly data as fallback), a named, independently published, receivable third-party report, not a party's say-so.

Present Suitable Method. Direct summation of reported contracts_traded across every row for the period, with no adjustment, is capable of establishing an exact count against a numeric threshold at the precision claimed.

Present Defined Benchmark. A specific numeric threshold N, stated in U.S. dollars, is named as the comparator.

Present Conclusive Link. Exceeding N is definitionally the Yes outcome; meeting the standard directly establishes the claim.

Present Comprehensive Coverage. Computation covers every reported transaction on Gemini Titan for the full population of the Reference Period, not a sample, matching the claim's scope.

Present Relevant Timeline. Reference Period is precisely bounded to the calendar month's trade dates, matching the obligation period exactly.

Corrections and Restatements finality

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

Determination: the Reference Volume as reported by the Determination Cutoffis the final figure for settlement · Consequence: the Reference Volume is computed once and settlement is not revisited, even if later corrected

Present Independent Verification. Evidence is the same published Gemini Titan reports as of a fixed cutofftime, a concrete and receivable source.

Present Suitable Method. A fixed-time snapshot procedure can reliably establish 'the value as of cutoff,' which is exactly what the clause claims (not ongoing accuracy).

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

Present Conclusive Link. Reaching the cutoffwith published data definitionally yields the final Reference Volume under the clause's own terms.

Present Comprehensive Coverage. Covers the full Reference Period data set as published, matching the claim's scope.

Present Relevant Timeline. The bounded one-time cutoffmatches the clause's own one-time determination obligation.

Change in Publication (void and return collateral)

“Market Outcome has not been unequivocally determined, all orders ... are void”

Determination: Gemini Titan has stopped/materially changed publication and the Market Outcome cannot be unequivocally determined · Consequence: all orders on the Contract are voided and collateral is returned

Partial Independent Verification. Stoppage of publication is objectively observable, but 'materially changes' and 'unequivocally determined' are the Exchange's own characterizations with no named third-party check.

Partial Suitable Method. Can detect an outright stoppage, but cannot reliably establish the more elastic 'material change' or 'unequivocal' determination at the certainty the clause implies.

Partial Defined Benchmark. Triggering conditions are listed but 'materially changes' and 'unequivocally determined' are undefined, elastic terms.

Partial Conclusive Link. Given the elasticity of the standard, satisfying it does not reliably or verifiably establish the claimed state of affairs.

Present Comprehensive Coverage. Applies to the specific Contract and its defined Reference Period data.

Present Relevant Timeline. Assessment is tied to the relevant Reference Period/cutofftiming of that Contract.

Absence of Data (void and return collateral)

“ProphetX cannot reasonably determine the outcome ... all orders ... void”

Determination: ProphetX cannot reasonably determine the Contract's outcome from any available source · Consequence: all orders on the Contract are voided and collateral is returned

Absent Independent Verification. Rests entirely on ProphetX's own satisfaction ('cannot reasonably determine'), with no named independent evidence or third-party check.

Absent Suitable Method. 'Reasonably determine' is not a checkable procedure; it is the Exchange's subjective assessment, not a method capable of establishing the claim at any defined certainty.

Absent Defined Benchmark. No threshold, test, or criteria are specified for what counts as being unable to 'reasonably determine' the outcome.

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

Partial Comprehensive Coverage. Applies to the specific Contract's outcome, but with no defined procedure it is unclear what population of data sources was actually checked.

Partial Relevant Timeline. No explicit window is stated for when this assessment occurs relative to the Determination Cutoff.

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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