Comment Text:
Enclosed herewith is a comment letter on the Commission's proposed interpretation of "actual delivery," as that term is used in Section 2(c)(2)(D) of the Commodity Exchange Act. This letter is being submitted on behalf of dYdX Trading, Inc. Please do not hesitate to contact us with any questions.
Andrew Cross across@perkinscoie.com
Laurie Rosini lrosini@perkinscoie.com
Perkins Coie LLP
