Will James Cook be the First Touchdown Scorer of Kansas City Chiefs vs. Buffalo Bills on November 26, 2026?

Railbird Exchange, LLC · received by the CFTC 30 October 2026 · the filing (PDF)

Summary

Warrant Check read 6 operative provisions in this filing. Across them, 26 of 36 checks are present, 6 partial and 3 absent. 3 provisions have every check present. 1 rule on who may trade is not a settlement term and is left out.

26 present6 partial3 absent1 not assessed

Staff-letter lens

The payout rule here is “Payout Criterion / Settlement Determination”: the rule that says what makes the contract pay Yes or No. The other 5 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 5 addressed
Settlement method described	Addressed	2 of 5 addressed
Covers every case it applies to	Addressed	4 of 5 addressed
Timing set	Addressed	4 of 5 addressed
Terms in the public filing	In the filing	4 of 5 in the filing

How the lens works and what it does not read

What the wording addresses

Payout Criterion / Settlement Determination — every check present.
“The Contract resolves YES if [entity] earns [achievement]”
Participation Determination: Defined Benchmark, Conclusive Link, Comprehensive Coverage, Relevant Timeline.
“[entity] has Participated if [entity] played in at least one”
Unconditionally Determined / Near-Complete Threshold Contingency: Defined Benchmark, Conclusive Link, Comprehensive Coverage, Relevant Timeline.
“Interrupted and does not Conclude within the Completion Window”
Mutually Exclusive Contracts Settlement Allocation — every check present.
“The aggregate payout across all Contracts in a Mutually Exclusive Set”
Position Accountability Level Reporting — every check present.
“A Member who holds or controls aggregate positions at or above”

What the wording leaves open

Participation Determination “[entity] has Participated if [entity] played in at least one”
- Independent Verification — Partial: Relies on snap count data from an unnamed 'data provider vetted and designated by the Exchange' - source exists but is not identified, and Exchange retains discretion over exceptions
- Suitable Method — Partial: Snap-count data can establish participation, but the clause admits the method may leave 'data gaps' requiring discretionary resolution rather than confirmed data
What would close it: Name the specific designated data provider and specify how data gaps/exceptions are resolved rather than leaving it to Exchange discretion
Market Outcome Review Process (erroneous/missing/unclear results) “the matter is referred to the Market Outcome Review Process”
- Independent Verification — Absent: Trigger is the Exchange's own determination that a result is 'clearly erroneous' - no named independent evidence or verification procedure
- Suitable Method — Absent: No described procedure exists in the supplied text for how 'clearly erroneous' is established; Rule 7.1 content is not provided
- Defined Benchmark — Absent: 'Clearly erroneous' is not defined by any named threshold or spec
- Comprehensive Coverage — Partial: Review appears to cover the single event's result but mechanics of scope (which data, which disputes) are not detailed
- Relevant Timeline — Partial: A 48-hour reporting window is named for one trigger, but the overall review process timing is otherwise undefined
- Relies on material referred to but not in the public filing.
What would close it: Include the text of Rule 7.1 (Market Outcome Review Process) defining the evidentiary standard, procedure, and timing for determining erroneous or missing results
Unconditionally Determined / Near-Complete Threshold Contingency “Interrupted and does not Conclude within the Completion Window”
- Independent Verification — Partial: Evidence is 'the game state at interruption as recognized by the governing body' - plausible neutral source but recognition mechanism not specified
- Suitable Method — Partial: Determining that 'no possible continuation' could change the outcome is a logical/certainty judgment not reducible to a simple objective check
What would close it: Specify how the governing body's 'recognition' of game state at interruption is documented or obtained

Every provision read

Payout Criterion / Settlement Determination

“The Contract resolves YES if [entity] earns [achievement]”

Determination: James Cook earned the First Touchdown Scorer achievement, officially confirmed by the Source Agency's Official Result · Consequence: Contract resolves YES (Settlement Value paid to longs) or NO (paid to shorts)

Present Independent Verification. Evidence is the Official Result from the NFL Game Statistics & Information System, a named independent third-party source, not a party's own say-so

Present Suitable Method. Official league statistics directly record who scored first, matching the strength of the factual claim asserted

Present Defined Benchmark. Standard named: the 'Official Result' / 'Official Statistics' as reported by the Source Agency

Present Conclusive Link. Meeting the named Official Result standard directly establishes the First Touchdown Scorer fact claimed

Present Comprehensive Coverage. Official Result covers the entire game, matching the claim's scope (whole game outcome)

Present Relevant Timeline. Official Result is based on the full game and corrections only count if made prior to Expiration, matching the 'full game' period claimed

Participation Determination

“[entity] has Participated if [entity] played in at least one”

Determination: James Cook Participated in the event (played at least one snap) · Consequence: If not Participated, Contract resolves to last fair market price instead of normal binary settlement

Partial Independent Verification. Relies on snap count data from an unnamed 'data provider vetted and designated by the Exchange' - source exists but is not identified, and Exchange retains discretion over exceptions

Partial Suitable Method. Snap-count data can establish participation, but the clause admits the method may leave 'data gaps' requiring discretionary resolution rather than confirmed data

Present Defined Benchmark. Threshold named: at least one offensive, defensive, or special-teams snap

Present Conclusive Link. One recorded snap, if confirmed, does establish Participation as defined

Present Comprehensive Coverage. Coverage is the entire event (the game), matching the claim's scope

Present Relevant Timeline. Snap data covers the whole game, matching the Participation claim's temporal scope

Market Outcome Review Process (erroneous/missing/unclear results)

“the matter is referred to the Market Outcome Review Process”

Determination: A reported result is 'clearly erroneous,' unreported within 48 hours, or otherwise requires review · Consequence: Exchange determines payouts, potentially resolving to last fair market price, via Rule 7.1 process

Absent Independent Verification. Trigger is the Exchange's own determination that a result is 'clearly erroneous' - no named independent evidence or verification procedure

Absent Suitable Method. No described procedure exists in the supplied text for how 'clearly erroneous' is established; Rule 7.1 content is not provided

Absent Defined Benchmark. 'Clearly erroneous' is not defined by any named threshold or spec

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. Review appears to cover the single event's result but mechanics of scope (which data, which disputes) are not detailed

Partial Relevant Timeline. A 48-hour reporting window is named for one trigger, but the overall review process timing is otherwise undefined

Unconditionally Determined / Near-Complete Threshold Contingency

“Interrupted and does not Conclude within the Completion Window”

Determination: The game state meets the Near-Complete Threshold or is otherwise Unconditionally Determined · Consequence: Contract is deemed complete and settles on the Official Result or game state at interruption

Partial Independent Verification. Evidence is 'the game state at interruption as recognized by the governing body' - plausible neutral source but recognition mechanism not specified

Partial Suitable Method. Determining that 'no possible continuation' could change the outcome is a logical/certainty judgment not reducible to a simple objective check

Present Defined Benchmark. Numeric threshold named: 10 or fewer minutes of Regulation Game Time remaining, or regulation ended

Present Conclusive Link. Meeting the stated threshold is defined to constitute deemed completion by the clause's own terms

Present Comprehensive Coverage. Covers the whole game state at the relevant point, matching the claim's scope

Present Relevant Timeline. Completion Window (72 hours from last play) is explicitly defined and matches the contingency period

Mutually Exclusive Contracts Settlement Allocation

“The aggregate payout across all Contracts in a Mutually Exclusive Set”

Determination: Settlement values across linked contracts must sum to the Contract Size · Consequence: Remaining contracts' payouts are adjusted so aggregate equals Contract Size

Present Independent Verification. Built on each constituent contract's Official Result, the same neutral evidence source used for the base Payout Criterion

Present Suitable Method. Arithmetic reconciliation based on confirmed Official Results of each linked contract can establish the aggregate payout fact

Present Defined Benchmark. Standard named: aggregate payout must equal the Contract Size

Present Conclusive Link. Meeting the equality condition directly establishes correct allocation across the set

Present Comprehensive Coverage. Covers the full designated Mutually Exclusive Set, matching the claim's scope

Present Relevant Timeline. Allocation occurs at settlement, matching the obligation's timing

Position Accountability Level Reporting

“A Member who holds or controls aggregate positions at or above”

Determination: A Member's aggregate position is at or above the Position Accountability Level · Consequence: Member must provide position/strategy/hedging information and consents to Exchange instruction restricting position changes

Present Independent Verification. Based on the Exchange's own objective position records, a measurable quantitative account rather than a party's subjective claim

Present Suitable Method. Position records can precisely establish whether the numeric accountability level is met

Present Defined Benchmark. Threshold named: 125,000 contracts (Position Accountability Level)

Present Conclusive Link. Meeting/exceeding the numeric level directly establishes the reporting obligation as defined

Present Comprehensive Coverage. Covers the Member's aggregate positions, matching the claim's scope

Present Relevant Timeline. Measured on an intraday or end-of-day basis, matching the continuing nature of the obligation

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