Coalition for Political Forecasting Comment on Proposed Amendments to CFTC Proposal on Event Contracts

We are writing on behalf of the Coalition for Political Forecasting in response to the CFTC’s request for comments on its proposal on event contracts.

The Coalition for Political Forecasting is a nonpartisan, nonprofit organization that aims to liberalize regulations on political betting in order to serve the public interest.

The Coalition advocates for a community of researchers, traders, and philanthropists that sees real-money prediction markets and other betting platforms as advanced forecasting tools that can help humanity navigate an uncertain future by aggregating and refining predictions about political events. The Coalition seeks to advise the policymaking community on how betting on political events can improve democratic institutions, promote economic stability, and facilitate innovative research.

The Coalition submitted comments to the Commission on the issue of event contracts in July 2023. Except where noted in the comment below, the views we expressed in previous comments have not meaningfully changed. Rather than reiterating points that are applicable to the Commission’s latest request for points, we have attached our previous comment below.

In line with the core interest of our organization, we focus, in this comment, on the amendments’ implications for event contracts related to politics.

We hope that our arguments in this comment will encourage the Commission to modify the proposed amendments and take a deliberative approach to finalizing the proposal.

Sincerely,

Pratik Chougule
Executive Director, Coalition for Political Forecasting

Mick Bransfield
Research Director, Coalition for Political Forecasting

Solomon Sia

Board Member, Coalition for Political Forecasting

COALITION FOR POLITICAL FORECASTING

info@coalitionforpoliticalforecasting.org

202-860-4995

The Need for CFTC Rulemaking on Event Contracts

We support the Commission’s decision to initiate a notice of proposed rulemaking on event contracts as a means of providing regulatory clarity, certainty, and stability in the space.

The CFTC remains the federal agency best positioned to exercise jurisdiction over event contracts. Since 1992, when CFTC-registered exchanges increased their listing of event contracts, the Commission has gradually expanded its jurisdiction over the space. It is true that event contracts do not fall within the core regulatory remit of the CFTC. We agree, for instance, that key aspects of event contract regulation would be a better fit for a gaming regulator. But Congress addressed the CFTC’s authority over event contracts as part of the Dodd-Frank Act, has looked to the Commission since then for leadership on the issue, and has shown little indication to roll back the Commission’s jurisdiction.

The above point regarding the CFTC’s authority over event contracts is critical considering how frequently the proposed rule raises concerns about the Commission’s lack of specialized experience and jurisdiction on questions related to event contracts. Too often in the proposed amendments, the Commission cites perceived limitations in terms of its expertise and authority as a reason for curtailing event contracts. Ironically, as underscored by Commissioners Mersinger and Pham, the Commission may be overcorrecting by exceeding its legal authorities in restricting event contracts.

Given the absence of a better-situated agency, the Commission should instead err on the side of building the capacity within the agency to manage event contracts, and articulating to lawmakers and judges why an updated legal regime is necessary to regulate the evolving event contract space.

The CFTC should draw confidence from the way its historic regulation over event contracts has allowed the space to mature. Although the CFTC has taken a restrictive and cautious approach to regulating event contracts, it has also provided enough leeway for the space to develop. Even though the CFTC is bound by a regime in which the preponderance of federal and state law militates against event contracts, the agency is a relative outlier among its international counterparts in terms of how much it has permitted event contracts to be offered on regulated exchanges, platforms with no-action relief, and offshore sites. The Iowa Electronic Markets and PredictIt, as an example, would not have operated with regulatory certainty in the absence of the CFTC’s no-action letters. The success of these projects has inspired entrepreneurs to build event contract platforms of greater sophistication and value for the public interest.

We disagree with those who believe that this rulemaking is inherently problematic for the event contract space in light of the Commission’s reservations. Although we would favor a more laissez-faire approach to event contracts than what the Commission has pursued, we believe that a lack of regulatory certainty and clarity is perhaps as great an obstacle to the development of the event contract space as are regulations themselves.

The absence of clear rules has harmed the event contract space in three main ways.

First, it has deterred market entrants from participating in the space on the assumption that this decision would entail cost-prohibitive compliance measures, exposure to future enforcement actions, and poor returns on investment.

Second, regulatory ambiguity has encouraged market participants to offer and wager on betting lines with dubious public interest benefits, thereby inviting not only regulatory scrutiny but also negative public attention.

Third, attempts by both Commission staff and market operators in the space to interpret ambiguous rules and test their limits have escalated into policy reviews, notice and comment periods, lawsuits, and public discussions that have, in the aggregate, generated a backlash against event contracts.

Avoiding Regulatory Backlash

The CFTC is not pursuing rulemaking in a vacuum. Laws, regulations, court rulings, and precedents are not the only factors shaping the Commission’s decisions as they pertain to event contracts.

The core dilemma is that market demand for event contracts is growing at the same time that they face heightened scrutiny in the political arena.

The most politically sensitive event contracts—those pertaining to elections—are precisely the ones that tend to draw the most interest by market participants, the press, and researchers.

During previous reviews, the Commission was inundated with comments by members of Congress, grassroots organizations, and powerful lobbies opposing election contracts on DCMs. Their opposition speaks to the deep and widespread fears in American society about the intersection of betting and democratic institutions, as reflected in the strict laws that govern election betting at the state level.(3)

At the same time, the promise of event contracts is being realized in unprecedented ways. Event contracts related to elections and politics are thriving primarily due to the efforts of companies that are not registered as DCMs and/or that are not pursuing no-action relief from the CFTC. We believe that these markets would be more efficient if they operated with legal certainty and were more directly accessible to American users. But even with these limitations, the diversity of markets that are now available, and the volume, participation, and attention they are drawing would be impossible on a DCM even under the most laissez-faire of Commissions.

We continue to believe that event contracts on elections and other political events further the public interest.

However, we disagree with advocates of event contracts who are encouraging the CFTC to expend political capital, stretch its authority, and test the limits of the law by permitting a wide array of political event contracts. This is because the greatest threats to political event contracts no longer come from CFTC regulation. More concerning is the possibility that highly visible deliberations on the issue at the CFTC will harden legal precedents against event contracts and invite sweeping restrictions by Congress that usurp the CFTC’s prerogative to promote responsible innovation in the event contract space.

We fear, likewise, that enforcement arms of the U.S. government will seek to crack down not only against companies offering event contracts but also against users on these platforms.

Indeed, the highly restrictive legal regime in which event contracts are mired came about as a consequence of overzealous industries whose poor judgment provoked a regulatory backlash in the form of laws such as the Unlawful Internet Gambling Enforcement Act of 2006 and Dodd-Frank.

We, therefore, encourage the Commission to propose amendments that are not only consistent with the law but are also attuned to a political environment in which ignorance, strong moral intuitions, and unfavorable news cycles can lead to overreaction on emotionally charged issues such as election betting.

Provided that the Commission adopts the revisions we detail below, we believe that the proposed amendments will prevent regulatory backlash, allow select event contracts to operate on DCMs, provide non-registered entities with space to innovate, and support industry actors in their efforts to navigate regulations in the space.

The Definition of Gaming

As noted in the proposed amendments, the definition of gaming as it pertains to event contracts is ambiguous. While we favor as a policy matter a relatively narrow definition of gaming, we believe that each of the commissioners, as well as lawyers representing the CFTC, Kalshi, and various public interest groups, have all offered reasonable arguments that will be adjudicated in the federal courts for the foreseeable future.

As these deliberations proceed, we would encourage the Commission to provide clarity on two of the most important types of event contracts that could be prohibited under an expansive definition of gaming.

Mention Markets

One is “mention” markets. Among the most important event contracts for the public interest are those that ask whether political leaders will say certain words on occasions such as debates and speeches. Mentions by political candidates of certain companies, legislation, and policy agendas can provide critical clues for market participants seeking to hedge or otherwise navigate economic risk. This is particularly true considering how sensitive financial markets can be to the words of political candidates. We would encourage the Commission to indicate clearly that these markets do not constitute gaming under the final approved amendments.

Legal Markets

The second is markets on the outcomes of legal cases. We are pleased to see that the Commission permits Kalshi to offer markets on the outcome of court decisions, which are highly pertinent to the public interest.(4) We are concerned, however, that an expansive reading of the amendments could interpret court cases as constituting a “contest of others”, thereby running afoul of the Commission’s definition of gaming.

The Commission should explicitly indicate which types of legal markets are permissible. Relatedly, it would be helpful for the Commission to explain why legal markets are acceptable, notwithstanding the perverse financial incentives they can create among a small number of highly influential insiders. Other event contracts are prohibited on these grounds despite the fact that the alleged perverse incentives to manipulate or degrade the integrity of democratic institutions are considerably weaker in these contexts, insofar as they exist at all.

To be clear, we are not suggesting that the Commission should prohibit legal markets. To the contrary, we are hoping that the Commission will bring greater clarity and consistency by treating comparable event contracts under an intuitive regulatory framework.

Economic Purpose Test

We strongly disagree with the proposal’s resurrection of the economic purpose test, which has limited relevance to event contracts.

The proposal relies heavily on a colloquy between Senators Feinstein and Lincoln in 2010. There is little evidence that either these senators or, for that matter, the staffers who may have inserted the language into the Congress Record, were contemplating dilemmas associated with event contracts in the political space. Indeed, they never even mentioned elections. The launch of PredictIt was more than four years away. Neither the technologies nor even the concepts on which crypto-based prediction markets exist today had been developed.

The economic purpose test’s emphasis on price basing and hedging utility may be relevant for traditional futures markets but are incidental to event contracts. While political and election event contracts can be and are occasionally used for hedging and price basing, the vast majority of activity in these markets is speculation, often in furtherance of price discovery, risk calculation, and quantifying uncertainty.

Over the past two decades, the CFTC has received comments from distinguished academics and market participants on the myriad ways event contracts relate to the public interest. Being novel technologies, the applications of event contracts are continuously being explored and expanded by researchers, entrepreneurs, and market participants.

The Commission itself has previously noted (correctly, in our view), that event contracts have value as “information aggregation vehicles.”(5) Likewise, in the current proposal, the Commission concedes that approval of the proposed amendments may result in the loss of “informational value.”

The question of how event contracts relate to the public interest calls for a test that is far more holistic, comprehensive, and nuanced than the economic purpose test.

Our recommendation is for the Commission to oversee a separate rulemaking process to determine appropriate tests on whether event contracts are contrary to the public interest. We believe that the rulemaking should convene after the 2024 U.S. elections. The Commission at this point would benefit from comments that draw on lessons learned from the performance of event contracts in elections with unprecedented activity and volume.

War, Terrorism, and Assassination Contracts

Considering the proposal’s strong denunciation of war markets, it makes little sense to us why the Commission is explicitly opting in the proposal not to define war. In many of the most consequential conflicts in the world, it is unclear whether a war is even occurring. Without a definition of war, event contract platforms will have little guidance on whether they can offer markets related to a wide array of current events.

Proposing a clear, narrow definition of war would help mitigate the possibility that a CFTC-regulated market would create a financial incentive to carry out an act of war. The CFTC, as an example, could define war as a type of conflict that could only be initiated by designated leaders of a country through formal, defined government processes. It is highly unlikely that political figures’ decision-making at this level would be motivated by an opportunity to profit illicitly from a small investment in a DCM, in which they are not permitted anyway.

The proposal does not sufficiently consider that event contracts related to war could be designed in ways that would be highly beneficial to the public interest as information sources and decision-making instruments, without meaningful perverse incentives.(6) For example, migrant flows driven by international conflicts are a source of economic risk. It is difficult to see how an event contract on a question like the number of refugees entering a country would create incentives for market participants to carry out a “heinous act” in this domain, much less how they would act on these incentives. Yet these contracts would facilitate price basing, hedging, and other useful information in furtherance of the public interest. We assume this is why the Commission already permits Kalshi to offer a contract on the number of “credible fear” asylum cases.

The ongoing conflict between Russia and Ukraine illustrates the above dilemmas. Whether or not the conflict had escalated into a “war” was a matter of debate in the early years of the conflict when Russian president Vladimir Putin referred to the country’s intervention as a “special military operation.” Event contracts could have been offered on the question of when, if ever, Russia or an international body would refer to their intervention in Ukraine as a “war.” Furthermore, as a consequence of the conflict, there are public interests at stake in questions such as how long Putin, Ukrainian president Vlodymyr Zelensky, and other influential world leaders in the conflict will remain in power, and how many refugees from Russia and Ukraine will enter neighboring countries.

Before approving the proposed amendments, the Commission should offer guidance on the definition of “war” and the type of events that can be offered without running afoul of the rule’s prohibition on war, terrorism, and assassination markets.

We also urge the Commission to clarify that event contracts related to political leaders’ tenure in office would not be prohibited due to the Commission’s opposition to terrorism, war, and assassination markets. Event contracts on when and for how long political leaders will remain in office are highly pertinent to the public interest. In the vast majority of cases, political leaders leave office due to factors incidental to war, terrorism, and assassination. At the same time, these factors could impact the length of any political leader’s exit—a reality traders in these markets need to consider even if they are difficult to quantify.

We are concerned that overzealous regulators will categorically ban event contracts on political leaders’ tenures in office on the grounds that they might create perverse incentives related to war, terrorism, and assassination.

To that end, the Commission should clarify under what circumstances, if any, political leader markets would run afoul of the rule’s prohibition on terrorism, war, and assassination markets.

Election Integrity

In our September 2022 comment, we cited UK political betting markets as evidence that concerns about the impact of election contracts on democratic institutions are overstated:

The Commission may find inspiration in the way the UK has approached the regulation of election contracts. Many of the concerns that animate the Commission’s deliberations today weighed on British regulators in the mid-20th century in the context of political betting shops. The UK’s thriving election markets, which have enriched British public life without threatening the integrity of the institutions, speaks to their potential in the United States.

Recent events in the UK weaken these arguments.

Reports that the UK Gambling Commission was investigating senior officials for betting on the timing of the elections—potentially with the benefit of inside information—have affected, at a minimum, perceptions of election integrity.(7)

The UK investigation provides an ideal case study to consider the relation between election integrity and political betting, and draw appropriate lessons for the United States.

We believe it would be prudent for the Commission to wait for the UK Gambling Commission to release its findings so that the Commission can consider them before approving the amendments. We recommend that the Commission convene roundtables and other opportunities for experts to testify on the UK investigation, its fallout, and lessons for the CFTC’s regulation of the space.

Discerning Between Retail Traders and Billionaires

Public comments in support of this rule are focused on how “billionaires” could take advantage of prediction markets. What these comments ignore is that this rule targets retail traders. Billionaires would be largely affected. Wealthy individuals (i.e. “Eligible Contract Participants”) are allowed to engage in swaps under the Commodity Exchange Act (CEA), and would be unaffected by this rule. And billionaires can easily afford to travel to another country where betting on American politics is legal and without limit. Moreover, for large investors, the zero-sum nature of event contracts makes them less attractive than equities closely correlated to election outcomes like health care or defense stocks.

Misinformation and Manipulation of Election Event Contracts

The proposed rule fails to put in proper context the incentives that election event contracts create regarding misinformation and inaccurate information.

The proposed rule claims that “false reporting or other misinformation—such as inaccurate polling, voter surveys or false news reporting—could be used to distort the information underlying price formation.”

In footnote 125, the Commission acknowledges counter-arguments that were offered repeatedly in previous comments: “event contracts involving occurrences in connection with political election contests could serve as a check on misinformation and inaccurate polling, stating that market-based alternatives tend to be more accurate than polling or other methods of predicting election outcomes.” The Commission responds by noting “research suggesting that election markets may incentivize the creation of ‘fake’ or unreliable information in the interest of moving the market.”

It is true that political event contracts incentivize both attempts at manipulating markets with misinformation,as well as attempts to correct inaccurate information.

However, available evidence suggests that incentives to correct inaccurate information are considerably stronger than incentives to spread misinformation, as seen by how quickly markets self-correct after reacting to these sources.

The Commission has never provided evidence to the contrary. In the DC federal court hearing in Kalshi v. CFTC, for example, Judge Cobb asked about the economic benefits of election contracts. CFTC attorney Anne Stukes responded that, “the Commission determined in its discretion that those were not outweighed by the very serious public interest” stakes regarding election integrity. Neither Stukes nor the proposed amendments explain what precise balancing test the Commission used to determine the relative interests on both sides.

Rather than prohibiting election contracts on the basis of its manipulation concerns, we believe that the Commission should develop a balancing test on whether incentives to create inaccurate information are outweighed by incentives to promote truthful information of value to the public interest. The proposed amendments on event contracts should not be finalized until the public has had an opportunity to comment on this balancing test.

A well-conceived balancing test would encourage registered entities to create lines that further the public interest, and traders and other market participants to engage these contracts with integrity.

Implementation Timeline

We strongly encourage the Commission to avoid submitting the final rule amendments for publication until after the 2024 U.S. elections.

Event contracts on the 2024 U.S. election will provide unprecedented data and insights that should inform the Commission’s deliberations. We recommend that the Commission provide the public with an opportunity to comment on the proposed amendments based on an understanding of how political betting markets performed in the elections.

For the amendments to achieve their stated goal of creating regulatory clarity, they will need a strong, bipartisan political mandate. This will be difficult to achieve without knowing the outcome of the 2024 presidential elections. This election is unique in the sense that one of the major party candidates is a former president whose administration oversaw landmark reforms in the regulation of event contracts. President Trump is exceptional among major party presidential candidates in the way he openly and frequently references political betting odds on the campaign trail. More so than any recent presidential election, a contest between Trump and Kamala Harris would be a referendum on how the American people see the issue of political event contracts.

Differences among the current Commissioners fuel perceptions that the Commission is divided on the issue of event contracts along partisan lines, and that reforms in the space are subject to change depending on the partisan makeup of the Commission. While we agree with Commissioner Goldsmith Romero’s sentiments in the Open Meeting that the Commissioners do not think about these issues through partisan filters, the reality is that the historically non-partisan issue of event contract regulation has in fact become more ridden by partisan divides in recent years, as seen by the comments the Commission has received from Congress. We believe that it will be easier for the Commission to find a greater consensus on the issue after the 2024 elections regardless of the outcome.

The Commission is more likely to garner public approval for the amendments and lay the groundwork for a durable regulatory regime if it waits for the outcome of the 2024 election, integrates lessons from the elections, and drives greater consensus among the Commissioners.

A Lack of Comparative Analysis

In his statement in Appendix 2, Chairman Behnam asserts that political event contracts “degrade the integrity of the uniquely American experience of participating in the democratic electoral process.” Behnam has used similar terms in interviews he has conducted on the issue.

Behnam’s point merits criticism in the context of the Commission’s proposal. While American democracy has unique characteristics (as every other democracy does), participation in democratic electoral processes is hardly unique to the American experience.

Many countries—including liberal democracies with legal regimes, electoral processes, and political cultures similar to the United States—have undertaken thoughtful reviews of how political event contracts relate to their electoral processes. Some, such as the UK and Australia have adopted relatively permissive regulations on political event contracts while others have taken a more stringent approach.

Behnam’s dubious claim speaks to a larger issue that has undermined the Commission’s deliberations on event contracts. The totality of the Commission’s reviews on event contracts has been undertaken with a conspicuous lack of curiosity about the experiences of other countries. Not surprisingly, the proposal does not even make passing reference to markets outside of the United States.

We believe that the Commission should convene roundtables with experts from around the world who can speak to how their countries have weighed dilemmas associated with the relation between political event contracts and democratic institutions. This exercise would be beneficial to the Commission generally given its growing participation in international initiatives. Comparative analyses should not only inform any amendment in this space but should be explicated by the Commission.

Constitutional Objections

Throughout the Commission’s review of event contracts, critics have raised constitutional questions that the Commission has refused to address.

In our previous comments, we have raised concerns that the Commission’s regulations on political event contracts violate the First Amendment.

Commissioner Pham, in her dissent, raises compelling arguments pertaining to the Tenth Amendment and the Supreme Court’s preemption doctrine.

The Commission ought to address these constitutional objections as part of any final proposal.

Responding to Comment Letters

Throughout its review of event contracts, the Commission has not engaged sufficiently with arguments raised in public comments.

The only indication we have seen that the Commission contended with our arguments came not through the Commission’s notice and comment periods, but rather, at the DC federal court hearing in Kalshi v. CFTC, where Jones Day attorney Amanda Rice referenced our comment.

All of us have used our platforms to encourage the public to submit comments to the Commission on the assumption that the agency will consider them in good faith. The Commission’s failure to respond directly to the comments that we and others have provided has been noted by high-profile participants in the event contract space. One prominent market participant told us that he now regards the CFTC’s requests for comments as little more than “public theater” and is looking to the judiciary to provide clarity.

Before issuing a final rule, the Commission should respond directly to the comments it has received. Doing so is not simply a matter of good government; it will help build a political mandate for the Commission’s final amendments.

Markets Correlated with Elections

Even if the Commission finalizes the amendments, demand will not diminish for election markets. This creates an incentive for registered entities to offer event contracts that are ostensibly about economic or financial indicators but are so highly correlated with elections that they function as proxies for election contracts.

The Commission should clarify what its current position is on this issue and how the proposed amendments would speak to this question.

Given the ease with which correlated markets can be offered and marketed, we are skeptical that the Commission could effectively regulate them out of existence, at least in a resource-efficient manner. At most, a restrictive CFTC rule on the matter might create transaction costs for market operators in reaching low-information retail traders.

Enforcement

The proposed amendments would provide clarity for the relatively small number of market operators that are committed to playing by the CFTC’s rules, inclined to err on the side of caution in their self-regulatory responsibilities, and willing to expend the resources necessary to seek Commission approval.

In our estimation, there is currently only one market operator, Kalshi, that fits this profile. An irony of the CFTC’s approach to event contracts is that Kalshi, more than any other market operator in the space, has been stymied by the Commission. Those platforms that have chosen not to register with the CFTC and avoid or evade Commission rules have been among the biggest winners in the space.

The demand for event contracts creates incentives for market operators to facilitate investments of dubious legality by offering the maximum number of markets possible and by engaging in minimal efforts when it comes to enforcing requirements related to fraud, false reporting, manipulation, market integrity, and other CFTC concerns. This dynamic is among the factors that led to litigation between the CFTC and PredictIt.

While finalizing the rule would impact the event contract space, the ways that the rule is enforced, in our judgment, will prove to be the more significant factor affecting how event contracts influence the public interest.

Discussion of enforcement is conspicuously absent in the proposed text.

As seen from the Commission’s open meeting on May 10, it is not just market participants, but also the Commissioners themselves that lack clarity on the enforcement implications of the rule. We agree with Commissioner Goldsmith Romero that the refusal of the CFTC enforcement division to attend the meeting is “very disappointing”, “unacceptable”, and a “dereliction of their duties.” As Commissioner Goldsmith Romero indicated, the brief statement that the enforcement division submitted did not allow for adequate opportunity for question and follow-up.(8)

The enforcement division’s absence speaks to larger issues with the proposal. Generally, it seems to legitimate the points Commissioner Pham made in the open hearing as well as her dissent about the need for reform in terms of how the Commission is handling rulemaking processes.

Specific to event contracts, it indicates that the Commission is riven with internal disagreement. This is neither surprising nor problematic per se, given the complexities and uncertainties associated with the issue. Indeed, the absence of disagreement would point to a more concerning lack of reflection.

The lack of agreement within the agency does, however, call for the Commission to take a slower, more deliberative approach to the proposed amendments. Without a consensus between the Commissioners, the staff, and the enforcement division of the CFTC, the Commission will not be able to generate enough buy-in for the proposal to create stability in the space.

Event contract regulation will instead be seen as a tentative, political question that is up for grabs depending on the outcome of elections and the make-up of the Commission at any given point.

Relying on tips and referrals from market participants for the underlying information sources needed for enforcement actions presents its own dilemmas. In a fledgling but competitive, somewhat zero-sumindustry, this type of enforcement regime creates incentives for market operators and aggrieved traders to bring opportunistic complaints to the Commission in pursuit of market advantage. We believe that these dynamics have been at play in Kalshi’s repeated decision to draw regulatory attention to the practices of its competitors—a business strategy that dragged the entire event contract space into a political quagmire.

Enforcement actions and corresponding litigation in the event contract space are a poor use of the Commission’sresources. While the Commission should underscore to market participants their responsibilities related to self-regulation, it should also set realistic expectations with Congress and the public about the Commission’slimitations in the enforcement sphere. While reliance on self-regulation can expose the public to risks, these challenges will be far worse if the Commission encourages the event contract space to migrate offshore and/or to black markets.

Endnotes

1.  See, for example, the past contracts identified in Pratik Chougule and Solomon Sia, Political Betting Regulation in the United States: Pathways to Liberalization, July 2023, pp. 34-36.

2.  Chougule, host, “CFTC Cracks Down on Election Contracts,” Star Spangled Gamblers (podcast), 2 June 2024, https://starspangledgamblers.libsyn.com/cftc-cracks-down-on-election-contracts; Chougule, host, “Labour Is Headed for a Landslide Victory,” Star Spangled Gamblers (podcast), 25 June 2024, https://starspangledgamblers.libsyn.com/labour-is-headed-for-a-landslide-victory.

3.  Chougule and Sia, pp. 13-41.

4. On the public interest value of prediction markets on court cases, see Miriam A. Cherry & Robert L. Rogers, Tiresias and the Justices: Using Information Markets to Predict Supreme Court Decisions, 100 NW. U. L. REV. 1141, 1152– 58 (2006).

5.  CFTC, Concept Release on the Appropriate Regulatory Treatment of Event Contracts,” 73 Fed. Reg. 25,669 (2008), https://www.cftc.gov/lawandregulation/federalregister/proposedrules/2008/e8-9981.html 

6.  For background on war markets, see Manifold Markets, “Predicting War Markets by Douglas Campbell and Abhishek Kylasa” YouTube video, 11 October 2023, https://youtu.be/YrhsSohbRO4?si=NZZ7HVuOgOcFyaOJ 

7.  William Booth and Karla Adam, “What an election betting scandal says about British politics and culture,” Washington Post, 27 June 2024, https://www.washingtonpost.com/world/2024/06/26/what-an-election-betting-scandal-says-about-british-politicsculture/; Philip Conneller, “UK Election: Betting Scandal Helps Propel Keir Starmer to Historic Win,” Casino.org, 5 July 2024, https://www.casino.org/news/uk-election-betting-scandal-helps-propel-kier-starmer-to-historic-win/ 

8.  CFTC, “Copy of CFTC to Hold a Commission Open Meeting May 10,” YouTube video, 20 May 2024, https://youtu.be/u4p7jdfRQvQ?si=_sdWRW3y2hqhUY7P&t=4518