Will Donovan Mitchell record more points than all other players in NBA Cleveland Cavaliers at Atlanta Hawks on October 29, 2026?

Underdog Exchange DCM, Inc. · received by the CFTC 27 October 2026 · the filing (PDF)

Summary

Warrant Check read 7 operative provisions in this filing. Across them, 34 of 42 checks are present, 4 partial and 3 absent. 5 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.

34 present4 partial3 absent1 not assessed

Staff-letter lens

The payout rule here is “Main Payment Criterion (sole leader)”: 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	5 of 6 addressed
Settlement method described	Addressed	4 of 6 addressed
Covers every case it applies to	Addressed	5 of 6 addressed
Timing set	Addressed	5 of 6 addressed
Terms in the public filing	In the filing	6 of 6 in the filing

How the lens works and what it does not read

What the wording addresses

Main Payment Criterion (sole leader) — every check present.
“Entity records a value of Stat strictly greater than”
Shared-Leader Tie Payment — every check present.
“tie at the highest value, Yes pays $1/n”
Source Agency Publication/Fallback: Independent Verification, Suitable Method, Comprehensive Coverage, Relevant Timeline.
“has not published the information necessary to determine”
Game Delay/Cancellation Thresholds — every check present.
“delayed for more than 48 hours, all markets”
Entity/Competitor One-Second Participation Rule — every check present.
“player must play at least one (1) second”
Official Statistical Corrections — every check present.
“Official statistical corrections published before Expiration supersede”

What the wording leaves open

Source Agency Publication/Fallback “has not published the information necessary to determine”
- Defined Benchmark — Partial: 'Information necessary to determine the Expiration Value' is contextually defined but not given a precise content threshold.
- Conclusive Link — Partial: Publication by a ranked source generally establishes the needed fact, but 'necessary information' boundary is loosely drawn.
What would close it: Define more precisely what counts as 'information necessary to determine the Expiration Value.'
Material Format Change Discretion “materially affects markets on Game, the affected”
- Independent Verification — Absent: Determination is made solely by the Exchange ('as determined by the Exchange'), not via named external evidence.
- Suitable Method — Absent: No procedure specified to assess 'material effect'; purely discretionary judgment.
- Defined Benchmark — Absent: 'Materially affects' is undefined, with no threshold or metric given.
- Comprehensive Coverage — Partial: 'Affected markets' is referenced but not tied to a defined set or measurable boundary.
- Relevant Timeline — Partial: No explicit time window for when the format-change assessment occurs relative to Game.
What would close it: Define objective criteria/thresholds for 'material' format changes and which markets are affected.

Every provision read

Main Payment Criterion (sole leader)

“Entity records a value of Stat strictly greater than”

Determination: Entity's official Stat value exceeds every comparison unit's value during the fixed Time Period · Consequence: Yes holder paid $1 per Contract; No holder paid $0

Present Independent Verification. Evidence is the official NBA box score and/or play-by-play, a named third-party record, not a party's opinion.

Present Suitable Method. Official box score records exact point counts, sufficient to establish a strict numerical comparison.

Present Defined Benchmark. Standard named: official NBA statistic as recorded in box score/play-by-play, with defined fallback hierarchy.

Present Conclusive Link. A higher recorded value in the official record directly satisfies the strictly-greater-than criterion.

Present Comprehensive Coverage. Competitor pool ('all other players') is mechanically determined via roster/participation rules matching the claim's population.

Present Relevant Timeline. Time Period fixed to 'entire game including overtime,' matching the obligation's duration.

Shared-Leader Tie Payment

“tie at the highest value, Yes pays $1/n”

Determination: Entity and n-1 other units are tied at the highest recorded Stat value · Consequence: Fractional payment $1/n to Yes, complement to No

Present Independent Verification. Same official box score evidence used to detect exact ties, including zero-zero ties.

Present Suitable Method. Box score can precisely identify equal values among units, including the zero-tie exception for missing-data distinction.

Present Defined Benchmark. Standard: official statistics show equal highest value for every eligible unit; missing data excluded from zero.

Present Conclusive Link. Meeting the equal-highest-value standard directly establishes the tie claim.

Present Comprehensive Coverage. Tied units counted per defined aggregate/individual unit rules matching competitor population.

Present Relevant Timeline. Same fixed Time Period applies to tie assessment as to the main criterion.

Source Agency Publication/Fallback

“has not published the information necessary to determine”

Determination: Necessary official information is unavailable at Expiration Time, triggering escalation · Consequence: 48-hour deferral, then ranked secondary sources, then fair-market-price fallback

Present Independent Verification. Evidence is publication status of named sources (NBA, ESPN, CBS Sports, Fox Sports), third-party and checkable.

Present Suitable Method. Procedure can establish whether publication occurred at a given time; it is a factual, time-stamped check.

Partial Defined Benchmark. 'Information necessary to determine the Expiration Value' is contextually defined but not given a precise content threshold.

Partial Conclusive Link. Publication by a ranked source generally establishes the needed fact, but 'necessary information' boundary is loosely drawn.

Present Comprehensive Coverage. Escalation applies only to the single named Game/Underlying, matching claim scope.

Present Relevant Timeline. Specific 48-hour windows and sequencing define the time covered by the evidentiary check.

Game Delay/Cancellation Thresholds

“delayed for more than 48 hours, all markets”

Determination: Game is delayed, cancelled, or abandoned beyond stated time thresholds · Consequence: Markets resolve to last fair market price (or settle from completed-period stats)

Present Independent Verification. Evidence is the game's scheduling/completion status, an observable, third-party-verifiable fact (NBA schedule/broadcast).

Present Suitable Method. Elapsed time and game status can be measured precisely against the stated clock thresholds.

Present Defined Benchmark. Clear numeric thresholds named: 48 hours delay, 48 minutes of gameplay, etc.

Present Conclusive Link. Crossing the named thresholds directly triggers the specified consequence as drafted.

Present Comprehensive Coverage. Applies to the single fixed Game and its defined sub-periods.

Present Relevant Timeline. Thresholds are expressed in explicit time units matching the obligation's relevant period.

Entity/Competitor One-Second Participation Rule

“player must play at least one (1) second”

Determination: Player did or did not play at least one second of Game · Consequence: Markets settle on recorded stats if played; else resolve to fair market price

Present Independent Verification. Evidence is official play-by-play/participation record, a neutral third-party document.

Present Suitable Method. Play-by-play precisely logs participation down to seconds, matching the asserted precision.

Present Defined Benchmark. Clear threshold: at least one (1) second of game participation.

Present Conclusive Link. Meeting/missing the one-second threshold directly determines which settlement path applies.

Present Comprehensive Coverage. Rule applies individually to the named Entity and each named competitor unit, matching claim population.

Present Relevant Timeline. Participation is measured across the full Game, matching the Time Period covered.

Official Statistical Corrections

“Official statistical corrections published before Expiration supersede”

Determination: A correction to official statistics was published before Expiration · Consequence: Corrected record controls settlement; later corrections ignored

Present Independent Verification. Evidence is the official NBA correction publication, a named, receivable document.

Present Suitable Method. Publication timing and content can be objectively verified against the record.

Present Defined Benchmark. Clear temporal standard: published before vs. after Expiration.

Present Conclusive Link. Timing relative to Expiration directly determines whether the correction is controlling.

Present Comprehensive Coverage. Applies to the same official statistic and comparison units as the main claim.

Present Relevant Timeline. Expiration Date/Time cutoffprecisely bounds the relevant period.

Material Format Change Discretion

“materially affects markets on Game, the affected”

Determination: A format change to Game 'materially affects' the markets · Consequence: Affected markets may be resolved to last fair market price

Absent Independent Verification. Determination is made solely by the Exchange ('as determined by the Exchange'), not via named external evidence.

Absent Suitable Method. No procedure specified to assess 'material effect'; purely discretionary judgment.

Absent Defined Benchmark. 'Materially affects' is undefined, with no threshold or metric given.

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

Partial Comprehensive Coverage. 'Affected markets' is referenced but not tied to a defined set or measurable boundary.

Partial Relevant Timeline. No explicit time window for when the format-change assessment occurs relative to Game.

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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