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Comment for Proposed Rule 91 FR 12516

  • From: Thomas N Ellsworth
    Organization(s):
    Lion Holdings Group LLC
    Valuetainment LLC

    Comment No: 115370
    Date: 4/30/2026

    Comment Text:

    Prediction markets have become an element of not only the national narrative, but news itself. Our podcast is our product. Our podcast audience trusts our calls, and prediction markets are a key input. Our transparent analysis, the calls we make, and the way we present them is what people are tuning in to hear.

    Elections are just one piece of the puzzle, and prediction markets make our election coverage even better in a world where better means WE WERE CORRECT. The same dynamic is playing out in sports, interest rates, and across the broader economy. Whether it’s who’s going to win on Sunday, where the Fed is likely to move next, or how key economic indicators will shake out, we’re seeing more and more cases where users, real people with skin in the game, are collectively out-performing the pundits and the panel shows. How? They are aggregated in appropriately managed and regulated prediction markets.

    That’s why we take prediction markets seriously as an input. They’re not a crystal ball, and they’re not infallible, but they do something traditional commentary and polling don’t: they force participants to be accountable. Users put money behind their point of view and live with the outcome. That discipline, across elections, sports, and macro, creates a signal we respect.

    Kalshi is one of the places where we watch those signals, alongside other data and traditional analysis. We look at what the markets are saying, we look at what the experts and institutions are saying, and then we do the work. The value we bring to our audience is that hybrid: market signals plus mainstream research, filtered through our experience and our voice. That mix of users versus pundits, and incentives versus opinions, is how we keep our content sharper, more grounded, and worthy of the trust our audience gives us.

    Along the way, prediction markets are getting it right. Broad user bases are more accurate than narratives delivered along the bias of a particular news source, and those traditional sources (market incumbents) are nervous. We think THAT is why the prediction markets are drawing fire.

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