Gemini Titan, LLC Product Self-Certification under 17 C.F.R. § 40.2(a) for “Will the Philadelphia Flyers have the worst record in the 2027 NHL regular season?” Event Contract.

Gemini Titan, LLC · received by the CFTC 26 October 2026 · the filing (PDF)

What the wording addresses

• Core Payout Criterion - worst record determination — every check present.
  “designate the Philadelphia Flyers as having the worst record”
• Tie-break resolution: Independent Verification, Comprehensive Coverage, Relevant Timeline.
  “the tie shall be resolved by the NHL’s official tiebreaking procedures”
• Postponed/cancelled game handling: Independent Verification, Suitable Method, Comprehensive Coverage, Relevant Timeline.
  “the result of the rescheduled game, once played, will be included”
• Season officially shortened — every check present.
  “the Contract shall settle based on the Source Agency’s final regular-season standings”
• Official designation finality — every check present.
  “The official designation reported by the Source Agency at the Expiration”
• Backup Source Agency hierarchy: Independent Verification, Suitable Method, Comprehensive Coverage, Relevant Timeline.
  “the Exchange may use the following, in hierarchical order, as a backup”

What the wording leaves open

• Tie-break resolution “the tie shall be resolved by the NHL’s official tiebreaking procedures”
  • Suitable Method — Partial: Procedure can rank tied teams but its content is not in the supplied text to verify it supports the claim.
  • Defined Benchmark — Partial: Standard named ('NHL's official tiebreaking procedures') but its substantive content is not reproduced.
  • Conclusive Link — Partial: If applied as described it would establish ranking, but cannot fully confirm without the procedures' text.
  • Relies on material referred to but not in the public filing.
  What would close it: Attach or incorporate the text of the NHL's official tiebreaking procedures so the standard can be verified.
• Postponed/cancelled game handling “the result of the rescheduled game, once played, will be included”
  • Defined Benchmark — Partial: 'NHL declares a final result' is referenced but no specific form or process for that declaration is defined.
  • Conclusive Link — Partial: If NHL declares a result, inclusion follows, but vagueness in what counts as a declaration weakens entailment.
  What would close it: Specify what constitutes an official NHL declaration of a final result for cancelled games.
• Season cancelled entirely “resolve to the last fair price determined in the sole discretion”
  • Independent Verification — Absent: Rests on the Exchange's own sole discretion, not any receivable third-party evidence.
  • Suitable Method — Absent: No procedure is specified; discretion cannot establish a verifiable settlement value.
  • Defined Benchmark — Absent: No named threshold, spec, or method for 'last fair price' is given.
  • Comprehensive Coverage — Absent: No defined population or data coverage underlies the discretionary determination.
  • Relevant Timeline — Absent: No defined time reference for the discretionary 'last fair price' determination.
  What would close it: Replace sole-discretion pricing with an objective fallback (e.g., last traded market price at a defined time, or an independent valuation methodology).
• Flyers withdrawal/forfeiture/disqualification “withdraw, forfeit, or are disqualified from the 2027 NHL season prior”
  • Independent Verification — Absent: Settlement value rests on Exchange's own discretion, not third-party-receivable evidence.
  • Suitable Method — Absent: No procedure specified to establish a price; discretion is not a checkable method.
  • Defined Benchmark — Absent: No threshold or methodology is named for 'last fair price.'
  • Comprehensive Coverage — Absent: No stated data population underlies the discretionary determination.
  • Relevant Timeline — Absent: No defined time reference for when 'last fair price' is assessed.
  What would close it: Define an objective fallback valuation method and reference point instead of sole Exchange discretion.
• Backup Source Agency hierarchy “the Exchange may use the following, in hierarchical order, as a backup”
  • Defined Benchmark — Partial: No definition is given for what makes the primary Source Agency 'not available.'
  • Conclusive Link — Partial: If unavailability is established, backup data would substitute adequately, but the undefined trigger weakens entailment.
  What would close it: Define objective criteria for 'not available' (e.g., non-publication within a stated time after games conclude).
• Market Outcome Review Process “the Exchange may, at its sole discretion, initiate the Market Outcome Review”
  • Independent Verification — Partial: Initiation is at Exchange's sole discretion; underlying Rule 7.1 process/evidence is not reproduced in the text.
  • Suitable Method — Partial: Cannot assess whether Rule 7.1's process can establish the claim since its content is absent.
  • Defined Benchmark — Absent: No standard or threshold for review or payout determination is stated in the supplied text; only a cross-reference to Rule 7.1.
  • Comprehensive Coverage — Partial: Scope of review (which outcomes, which data) is not defined beyond reference to Rule 7.1.
  • Relevant Timeline — Partial: Timing is only loosely bounded by 'before Settlement,' with no further limits specified here.
  • Relies on material referred to but not in the public filing.
  What would close it: Include or incorporate the text of Rulebook Rule 7.1 defining the review process, evidentiary standard, and payout determination method.

Every provision read

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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