Will Mito HollyHock score more goals than Sanfrecce Hiroshima in their J1 League match on October 31, 2026?

Underdog Exchange DCM, Inc. · received by the CFTC 23 October 2026 · the filing (PDF)

Summary

Warrant Check read 7 operative provisions in this filing. Across them, 37 of 42 checks are present, 5 partial and 0 absent. 1 provision has every check present. 1 rule on who may trade is not a settlement term and is left out.

37 present5 partial0 absent

Staff-letter lens

The payout rule here is “Payment Criterion - goal comparison determines settlement”: the rule that says what makes the contract pay Yes or No. The other 6 rules are fallback rules: what happens if the event is cancelled or delayed, the data goes missing, or the result is challenged.

Topic the staff letters raise	Payout rule	Fallback rules
Settlement source identified	Addressed	4 of 6 addressed
Settlement method described	Addressed	3 of 6 addressed
Covers every case it applies to	Addressed	6 of 6 addressed
Timing set	Addressed	6 of 6 addressed
Terms in the public filing	In the filing	0 of 6 in the filing

How the lens works and what it does not read

What the wording addresses

Payment Criterion - goal comparison determines settlement — every check present.
“strictly more final goals than Sanfrecce Hiroshima during the entire game”
Source unavailability fallback to last fair market price: Independent Verification, Defined Benchmark, Conclusive Link, Comprehensive Coverage, Relevant Timeline.
“none of the secondary Source Agencies has published the necessary information”
Pre-commencement cancellation fallback: Defined Benchmark, Conclusive Link, Comprehensive Coverage, Relevant Timeline.
“cancelled prior to its scheduled commencement and is not rescheduled”
Post-start cancellation/suspension - partial period resolution: Independent Verification, Suitable Method, Defined Benchmark, Conclusive Link, Comprehensive Coverage, Relevant Timeline.
“match officials have confirmed the conclusion of that segment”
Entire-game format cancellation - JAPANJLG declaration requirement: Independent Verification, Suitable Method, Defined Benchmark, Conclusive Link, Comprehensive Coverage, Relevant Timeline.
“Japan Professional Football League has declared the game's result to stand”
Team non-entry fallback: Independent Verification, Suitable Method, Defined Benchmark, Conclusive Link, Comprehensive Coverage, Relevant Timeline.
“does not participate in any officially recorded gameplay during Game”
Extended delay (>48h) fallback: Defined Benchmark, Conclusive Link, Comprehensive Coverage, Relevant Timeline.
“delayed for more than 48 hours, all markets on Game”

What the wording leaves open

Source unavailability fallback to last fair market price “none of the secondary Source Agencies has published the necessary information”
- Suitable Method — Partial: Checking named sources can establish non-publication, but the substituted LFMP outcome is a market-price proxy, not a determination of the actual underlying claim.
- Relies on material referred to but not in the public filing.
What would close it: Include the text of Rule 5.a.v describing how 'last fair market price' is calculated, since that mechanism is referenced but not supplied.
Pre-commencement cancellation fallback “cancelled prior to its scheduled commencement and is not rescheduled”
- Independent Verification — Partial: No named source (e.g., JAPANJLG notice) is specified for confirming cancellation or rescheduling status.
- Suitable Method — Partial: Whether a game was cancelled/rescheduled is objectively checkable in principle, but no procedure or confirming party is named.
- Relies on material referred to but not in the public filing.
What would close it: Name the confirming source/process for 'cancelled' and 'rescheduled' status, and supply Rule 5.a.v defining the LFMP calculation.
Post-start cancellation/suspension - partial period resolution “match officials have confirmed the conclusion of that segment”
- Relies on material referred to but not in the public filing.
What would close it: Supply Rule 5.a.v for the LFMP branch of this provision.
Entire-game format cancellation - JAPANJLG declaration requirement “Japan Professional Football League has declared the game's result to stand”
- Relies on material referred to but not in the public filing.
What would close it: Supply Rule 5.a.v for the LFMP fallback branch.
Team non-entry fallback “does not participate in any officially recorded gameplay during Game”
- Relies on material referred to but not in the public filing.
What would close it: Supply Rule 5.a.v for the LFMP calculation referenced here.
Extended delay (>48h) fallback “delayed for more than 48 hours, all markets on Game”
- Independent Verification — Partial: No named source is specified for confirming the delay or its duration.
- Suitable Method — Partial: Delay duration is objectively checkable in principle but no confirming party or document is named.
- Relies on material referred to but not in the public filing.
What would close it: Name the source confirming delay status and supply Rule 5.a.v for the LFMP mechanism.

Every provision read

Payment Criterion - goal comparison determines settlement

“strictly more final goals than Sanfrecce Hiroshima during the entire game”

Determination: Mito HollyHock scored strictly more official regulation-time goals than Sanfrecce Hiroshima · Consequence: Contract resolves Yes/No; long or short holders paid the Settlement Value

Present Independent Verification. Evidence is the official final result published by JAPANJLG (primary Source Agency), with named fallback to ESPN, CBS Sports, Fox Sports - third-party, receivable sources.

Present Suitable Method. Official final score records can establish a strict numerical goal comparison at the precision asserted.

Present Defined Benchmark. Named threshold: strictly more final goals during entire game excluding extra time; equal goals resolve No.

Present Conclusive Link. Meeting the stated goal-comparison threshold directly establishes the Yes/No outcome as defined.

Present Comprehensive Coverage. Claim and evidence both cover the single specified match between the two named teams.

Present Relevant Timeline. Only goals credited within the entire-game-excluding-extra-time period count, matching the claimed Time Period.

Source unavailability fallback to last fair market price

“none of the secondary Source Agencies has published the necessary information”

Determination: no primary or secondary Source Agency has published the result after the 48-hour waiting period · Consequence: Contract resolves to the last fair market price pursuant to Rule 5.a.v

Present Independent Verification. Non-publication by four named, checkable third-party sources is an objectively verifiable negative fact.

Partial Suitable Method. Checking named sources can establish non-publication, but the substituted LFMP outcome is a market-price proxy, not a determination of the actual underlying claim.

Present Defined Benchmark. 48-hour window and exhaustion of the named four-source hierarchy is a defined threshold.

Present Conclusive Link. Exhausting the named hierarchy without publication does establish 'information unavailable' as defined.

Present Comprehensive Coverage. Fallback applies to the same single specified match/market.

Present Relevant Timeline. 48-hour window tied to the Expiration Date/Time process.

Pre-commencement cancellation fallback

“cancelled prior to its scheduled commencement and is not rescheduled”

Determination: Game was cancelled before start and not rescheduled within 48 hours · Consequence: all markets on Game resolve to the last fair market price

Partial Independent Verification. No named source (e.g., JAPANJLG notice) is specified for confirming cancellation or rescheduling status.

Partial Suitable Method. Whether a game was cancelled/rescheduled is objectively checkable in principle, but no procedure or confirming party is named.

Present Defined Benchmark. 48-hour rescheduling window after original scheduled commencement is a clear threshold.

Present Conclusive Link. Satisfying 'cancelled and not rescheduled within 48 hours' is, by the clause's own definition, what triggers the LFMP outcome.

Present Comprehensive Coverage. Applies to all markets on the single specified Game.

Present Relevant Timeline. 48-hour window is measured from the original scheduled commencement, matching the pre-game period at issue.

Post-start cancellation/suspension - partial period resolution

“match officials have confirmed the conclusion of that segment”

Determination: a given Time Period was fully completed, as confirmed by match officials, before cancellation/suspension · Consequence: that segment resolves on the official record; incomplete segments resolve to last fair market price

Present Independent Verification. Match officials' confirmation is a named, receivable third-party determination.

Present Suitable Method. Match officials confirming conclusion of a segment (including stoppage time) can establish completion at the precision required.

Present Defined Benchmark. 'Fully completed' is defined as match officials confirming conclusion of the segment including stoppage/added time.

Present Conclusive Link. Meeting that confirmation standard directly establishes which resolution path (official record vs LFMP) applies.

Present Comprehensive Coverage. Applies segment-by-segment to the specific Time Period at issue in the specific Game.

Present Relevant Timeline. Completion is assessed as of the moment of cancellation/suspension, matching the claim's temporal scope.

Entire-game format cancellation - JAPANJLG declaration requirement

“Japan Professional Football League has declared the game's result to stand”

Determination: JAPANJLG has declared the game's result official despite cancellation/abandonment/suspension · Consequence: markets resolve on the official record; otherwise resolve to last fair market price

Present Independent Verification. A declaration by the named governing body (JAPANJLG) is a receivable, neutral third-party act.

Present Suitable Method. A formal league declaration can establish whether the result stands as official.

Present Defined Benchmark. Named standard: JAPANJLG has declared the result to stand as official.

Present Conclusive Link. Such a declaration directly determines which resolution path applies, as defined.

Present Comprehensive Coverage. Applies to the whole-game/whole-game-excluding-extra-time markets for the specified match.

Present Relevant Timeline. Declaration is assessed relative to the suspension/abandonment event, matching the claim's timing.

Team non-entry fallback

“does not participate in any officially recorded gameplay during Game”

Determination: the Team did not participate in any officially recorded gameplay · Consequence: all markets on Game resolve to the last fair market price

Present Independent Verification. Official gameplay records are a named, receivable evidentiary basis.

Present Suitable Method. Official records of participation can establish non-entry at the precision asserted.

Present Defined Benchmark. Named standard: no participation in any officially recorded gameplay.

Present Conclusive Link. Absence from the official record of gameplay directly establishes non-entry as defined.

Present Comprehensive Coverage. Covers the single specified Team and Game.

Present Relevant Timeline. Covers the entirety of the Game, matching the claim.

Extended delay (>48h) fallback

“delayed for more than 48 hours, all markets on Game”

Determination: Game has been delayed more than 48 hours from original scheduled commencement · Consequence: markets for uncompleted Time Periods resolve to last fair market price

Partial Independent Verification. No named source is specified for confirming the delay or its duration.

Partial Suitable Method. Delay duration is objectively checkable in principle but no confirming party or document is named.

Present Defined Benchmark. 48-hour threshold from original scheduled commencement is clearly stated.

Present Conclusive Link. Exceeding the 48-hour threshold is, by definition, what triggers the LFMP resolution for incomplete periods.

Present Comprehensive Coverage. Applies to markets tied to the relevant uncompleted Time Period of the specified Game.

Present Relevant Timeline. 48-hour measurement window matches the delay period being assessed.

Read 3 November 2026 with Warrant Check (instrument 1.0). Labels: Present, Partial, Absent describe whether each check is found in the wording as written. Not assessed: Conclusive Link cannot be judged where no Defined Benchmark is named; that follows from the missing benchmark and is not a separate gap.

Drafting a certification?

Have the draft read through the same lens before it is filed: privately, with nothing published. You get what the wording addresses and what it leaves open, term by term, including the fallback rules for cancellation, delay, missing data and challenged results, where gaps most often sit.

Ask for a private reading or check a single clause free →

← All filings in the monitor