Gemini Titan, LLC Self-Certification of an Event Contract Series under 17 C.F.R. § 40.2(d) for “Will {outcomes} occur in {events}?” (Multi-Leg Combination Event Contracts).

Gemini Titan, LLC · received by the CFTC 28 October 2026 · the filing (PDF)

Summary

Warrant Check read 5 operative provisions in this filing. Across them, 17 of 30 checks are present, 5 partial and 6 absent. 1 provision has every check present. 2 statements the exchange makes to the CFTC about the filing itself (such as that it complies with the Act) are not contract terms and are left out.

17 present5 partial6 absent2 not assessed

Staff-letter lens

The payout rule here is “Expiration Value / settlement formula”: 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	2 of 4 addressed
Settlement method described	Addressed	2 of 4 addressed
Covers every case it applies to	Addressed	2 of 4 addressed
Timing set	Addressed	1 of 4 addressed
Terms in the public filing	Kept elsewhere	1 of 4 in the filing

How the lens works and what it does not read

What the wording addresses

Eligible Components qualification: Independent Verification, Suitable Method, Defined Benchmark, Conclusive Link, Comprehensive Coverage.
“previously submitted a product certification or product filing”
Expiration Value / settlement formula: Independent Verification, Suitable Method, Defined Benchmark, Conclusive Link, Comprehensive Coverage, Relevant Timeline.
“Expiration Value of the Contract is the product of the settlement values”
Early settlement at $0.00 — every check present.
“Expiration Value of the Contract is thereby conclusively fixed at $0.00”

What the wording leaves open

Eligible Components qualification “previously submitted a product certification or product filing”
- Relevant Timeline — Partial: 'remain listed' implies a continuing status but no ongoing monitoring mechanism through the Contract's life is described
- Relies on material referred to but not in the public filing.
What would close it: Attach or cite the specific {rule} certifications for each eligible component to verify shared formula
Expiration Value / settlement formula “Expiration Value of the Contract is the product of the settlement values”
- Relies on material referred to but not in the public filing.
What would close it: Include the individual component {rule} texts to verify how each settlement value is itself evidenced
Unresolved component resolution “shall resolve that {component} in accordance with the applicable {rule}”
- Independent Verification — Partial: points to 'the Rulebook's provisions governing unresolved markets' and the component's own {rule}, neither of which is supplied
- Suitable Method — Absent: cannot assess whether the undisclosed procedure can establish a reliable settlement value
- Defined Benchmark — Absent: no specific threshold or method is stated in the text, only a cross-reference
- Comprehensive Coverage — Partial: applies to the single unresolved leg, but the procedure's coverage of that leg is undefined
- Relevant Timeline — Partial: bounded by the Expiration Date but the substantive timing of the undisclosed procedure is unclear
- Relies on material referred to but not in the public filing.
What would close it: Provide the Rulebook's unresolved-market provisions and the specific component {rule} to allow assessment of the resolution method
Market Outcome Review Process “the Exchange has the right to determine payouts pursuant to Rule 7.1”
- Independent Verification — Absent: rests on the Exchange's 'sole discretion' and an unprovided Rule 7.1, not neutral third-party evidence
- Suitable Method — Absent: 'sole discretion' is not a checkable procedure capable of establishing the claim at any defined certainty
- Defined Benchmark — Absent: no standard is stated beyond a cross-reference to Rule 7.1, whose content is absent
- Comprehensive Coverage — Absent: covers an open-ended set of scenarios (cancellation, forfeiture, disqualification, etc.) with no defined procedural coverage
- Relevant Timeline — Partial: limited to 'before Settlement' but the review process's actual duration is undefined
- Relies on material referred to but not in the public filing.
What would close it: Provide Rule 7.1's text defining the review criteria, evidentiary basis, and procedural safeguards for payout determination

Every provision read

Eligible Components qualification

“previously submitted a product certification or product filing”

Determination: a given component leg qualifies as an Eligible Component for inclusion in a Contract · Consequence: the component may be combined into a Series Contract

Present Independent Verification. relies on Part 40 certification/filing records and listing status - verifiable documents a third party (the Commission) could check

Present Suitable Method. checking filing and listing status can establish the binary eligibility claim

Present Defined Benchmark. named conditions: prior certification/filing, continued listing, shared multiplicative formula

Present Conclusive Link. meeting the three named conditions is defined as eligibility itself

Present Comprehensive Coverage. determination is made per individual component, matching the per-component claim

Partial Relevant Timeline. 'remain listed' implies a continuing status but no ongoing monitoring mechanism through the Contract's life is described

Expiration Value / settlement formula

“Expiration Value of the Contract is the product of the settlement values”

Determination: the product of component settlement values is the correct Expiration Value · Consequence: Contract payout amount is calculated and paid accordingly

Present Independent Verification. component settlement values derive from each component's own {rule}, implying third-party/Source Agency determined data

Present Suitable Method. mechanical arithmetic on already-established component values can establish the Expiration Value claim

Present Defined Benchmark. explicit formula named: product of settlement values, rounded down to the nearest cent

Present Conclusive Link. the formula is itself the definition of Expiration Value, so meeting it establishes the claim

Present Comprehensive Coverage. covers all component legs comprising the Contract as required

Present Relevant Timeline. calculation occurs after all legs resolved, matching the full obligation period

Early settlement at $0.00

“Expiration Value of the Contract is thereby conclusively fixed at $0.00”

Determination: one component resolving at $0.00 mathematically fixes the whole Contract's Expiration Value at $0.00 · Consequence: Contract settles immediately at $0.00 without waiting for other legs

Present Independent Verification. relies on a determinate, rule-resolved settlement value of a component (not a party's opinion)

Present Suitable Method. multiplication by zero is mathematically certain to yield zero regardless of other (non-negative) factors

Present Defined Benchmark. named trigger: any single component leg settling at exactly $0.00

Present Conclusive Link. the multiplicative formula logically entails a $0.00 product once one factor is $0.00

Present Comprehensive Coverage. applies to the whole Contract's legs as the formula requires

Present Relevant Timeline. settlement occurs immediately upon the triggering leg's resolution, matching the claimed immediacy

Unresolved component resolution

“shall resolve that {component} in accordance with the applicable {rule}”

Determination: an unresolved component leg can be properly resolved via Rulebook provisions to yield a valid settlement value · Consequence: Expiration Value is calculated and published despite the component not naturally resolving

Partial Independent Verification. points to 'the Rulebook's provisions governing unresolved markets' and the component's own {rule}, neither of which is supplied

Absent Suitable Method. cannot assess whether the undisclosed procedure can establish a reliable settlement value

Absent Defined Benchmark. no specific threshold or method is stated in the text, only a cross-reference

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. applies to the single unresolved leg, but the procedure's coverage of that leg is undefined

Partial Relevant Timeline. bounded by the Expiration Date but the substantive timing of the undisclosed procedure is unclear

Market Outcome Review Process

“the Exchange has the right to determine payouts pursuant to Rule 7.1”

Determination: the Expiration Value cannot be determined on the Expiration Date, warranting Exchange-determined payout · Consequence: Exchange unilaterally determines the Contract's payout outcome

Absent Independent Verification. rests on the Exchange's 'sole discretion' and an unprovided Rule 7.1, not neutral third-party evidence

Absent Suitable Method. 'sole discretion' is not a checkable procedure capable of establishing the claim at any defined certainty

Absent Defined Benchmark. no standard is stated beyond a cross-reference to Rule 7.1, whose content is absent

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. covers an open-ended set of scenarios (cancellation, forfeiture, disqualification, etc.) with no defined procedural coverage

Partial Relevant Timeline. limited to 'before Settlement' but the review process's actual duration is undefined

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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