Will the Primeira Liga match between SL Benfica and FC Alverca on November 2, 2026 have above 2.5 goals?

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

Summary

Warrant Check read 5 operative provisions in this filing. Across them, 23 of 30 checks are present, 1 partial and 5 absent. 3 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.

23 present1 partial5 absent1 not assessed

Staff-letter lens

The payout rule here is “Payment Criterion / Settlement Trigger”: the rule that says what makes the contract pay Yes or No. The other 4 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	3 of 4 addressed
Settlement method described	Addressed	2 of 4 addressed
Covers every case it applies to	Addressed	3 of 4 addressed
Timing set	Addressed	3 of 4 addressed
Terms in the public filing	In the filing	3 of 4 in the filing

How the lens works and what it does not read

What the wording addresses

Payment Criterion / Settlement Trigger — every check present.
“Payment Criterion encompasses the Expiration Value where n is above 2.5”
Source Agency Unavailability Fallback: Independent Verification, Suitable Method, Conclusive Link, Comprehensive Coverage, Relevant Timeline.
“resolve to the last fair market price pursuant to Rule 5.a.v”
Game Completion / Cancellation-Suspension Rules — every check present.
“settles from a controlling final goal total only if ... produces a final result”
Statistical Corrections Cutoff — every check present.
“corrections made in the official record prior to Expiration are incorporated”

What the wording leaves open

Source Agency Unavailability Fallback “resolve to the last fair market price pursuant to Rule 5.a.v”
- Defined Benchmark — Partial: ‘Necessary information’ for determining the Expiration Value is not precisely defined, leaving the trigger somewhat elastic.
What would close it: Define more precisely what constitutes the 'necessary information' that counts as publication.
Exhibit B Core Principles Compliance Discussion “[REDACTED]”
- Independent Verification — Absent: Entire content is redacted; no evidence of any kind is presented for review.
- Suitable Method — Absent: Cannot assess whether any procedure could establish the claim since the content is withheld.
- Defined Benchmark — Absent: No visible standard or threshold since the substantive discussion is redacted.
- Comprehensive Coverage — Absent: Coverage of which Core Principles/aspects are addressed cannot be determined from redacted text.
- Relevant Timeline — Absent: Cannot determine any time period covered by the redacted analysis.
- Relies on material referred to but not in the public filing.
What would close it: Supply the non-redacted Exhibit B compliance discussion, or a sufficient public summary, so the compliance claim can be evaluated.

Every provision read

Payment Criterion / Settlement Trigger

“Payment Criterion encompasses the Expiration Value where n is above 2.5”

Determination: the combined regulation-time goals (n) scored by both teams exceed 2.5 · Consequence: Expiration Value is set Yes/No and payment made to long or short position holders

Present Independent Verification. Evidence is the officially published final result from PORTLIGA (or named secondary agencies ESPN/CBS/Fox), a receivable third-party record, not a party's opinion.

Present Suitable Method. A direct count of goals from an official published result can establish the precise numeric claim asserted (n above 2.5).

Present Defined Benchmark. Named threshold: n above 2.5 (Count=2.5, Comparison=above).

Present Conclusive Link. Exceeding the named numeric threshold is precisely the claim being tested; no gap between standard and claim.

Present Comprehensive Coverage. Evidence covers combined goals of both named teams, matching the claim's population exactly.

Present Relevant Timeline. Time Period defined as entire game excluding extra time, matching the obligation period exactly.

Source Agency Unavailability Fallback

“resolve to the last fair market price pursuant to Rule 5.a.v”

Determination: none of the primary or secondary Source Agencies has published the necessary result information · Consequence: Contract settles to last fair market price instead of an actual goal-count outcome

Present Independent Verification. Non-publication is checked against named, receivable sources (PORTLIGA, ESPN, CBS Sports, Fox Sports) within fixed 48-hour windows.

Present Suitable Method. Checking whether named sources have published can establish the narrow negative claim (non-publication) at the certainty needed.

Partial Defined Benchmark. ‘Necessary information’ for determining the Expiration Value is not precisely defined, leaving the trigger somewhat elastic.

Present Conclusive Link. If no named source has published within the windows, the defined consequence (market-price settlement) follows directly by the clause's own terms.

Present Comprehensive Coverage. Hierarchy applies to the same single Game/Underlying the claim concerns.

Present Relevant Timeline. 48-hour waiting periods and hierarchical escalation are explicitly time-bound.

Game Completion / Cancellation-Suspension Rules

“settles from a controlling final goal total only if ... produces a final result”

Determination: whether a controlling final result covering the complete Time Period exists after cancellation, suspension, or abandonment · Consequence: Contract settles from the scoreline or falls back to last fair market price

Present Independent Verification. Evidence is the Source Agency's official final result (or its absence), a receivable third-party record.

Present Suitable Method. Checking for presence/completeness of an official final result for the full period can establish the binary claim asserted.

Present Defined Benchmark. Standard is a 'controlling final result for the complete Time Period,' a defined threshold tied to Source Agency hierarchy.

Present Conclusive Link. A complete, controlling final result for the period directly establishes the basis for settlement from that scoreline.

Present Comprehensive Coverage. Applies to the same single specified Game and Time Period as the claim.

Present Relevant Timeline. 48-hour resumption/publication windows explicitly bound the time covered.

Statistical Corrections Cutoff

“corrections made in the official record prior to Expiration are incorporated”

Determination: whether a goal attribution/correction was made before or after the Expiration Time · Consequence: correction is incorporated into settlement or disregarded

Present Independent Verification. Evidence is the timestamped official record of corrections, a receivable third-party document.

Present Suitable Method. Comparing a correction's timestamp to a fixed Expiration Time can establish the before/after claim precisely.

Present Defined Benchmark. Standard is explicit: correction timing relative to the defined Expiration Date/Time.

Present Conclusive Link. Timing relative to Expiration directly determines whether the correction is incorporated, matching the claim.

Present Comprehensive Coverage. Applies to the same official record and Game as the underlying claim.

Present Relevant Timeline. Cutoffis exactly the Expiration Time already defined elsewhere in the contract.

Exhibit B Core Principles Compliance Discussion

“[REDACTED]”

Determination: the Event Contract complies with applicable Core Principles for designated contract markets · Consequence: supports the overall certification that the contract complies with the Act and Regulations

Absent Independent Verification. Entire content is redacted; no evidence of any kind is presented for review.

Absent Suitable Method. Cannot assess whether any procedure could establish the claim since the content is withheld.

Absent Defined Benchmark. No visible standard or threshold since the substantive discussion is redacted.

Not assessed Conclusive Link. Not assessed: no Defined Benchmark is named, so whether meeting it would settle the question cannot be judged.

Absent Comprehensive Coverage. Coverage of which Core Principles/aspects are addressed cannot be determined from redacted text.

Absent Relevant Timeline. Cannot determine any time period covered by the redacted analysis.

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.

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