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Comment for Proposed Rule 91 FR 12516

  • From: Jennifer K. Kelly
    Organization(s):
    Katoji, LLC and SwarmDojo.com

    Comment No: 115378
    Date: 4/30/2026

    Comment Text:

    Please see attached document for comments concerning a clear, prospective pathway for blockchain-native peer-to-peer prediction platforms to operate legally in the US, through a commodity-nexus safe harbor from the gaming prohibition, formal recognition of on-chain controls as superior compliance tools, and a no-action letter framework for supervised soft launches.