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Comment for Proposed Rule 89 FR 48968

  • From: Jasper Merendino
    Organization(s):

    Comment No: 73718
    Date: 5/23/2024

    Comment Text:

    Dear Sirs,

    Since at least the time of Confucius, men of wisdom have admonished us to use correct terminology in deliberation.
    Failure to do this leads to all sorts of bad ideas. For example, the broad equation of all labor with "slavery" has resulted in some truly unsustainable economic notions bing bandied about in certain circles.

    The above very much applies to the proposed classification of prognostication as "gaming".
    Elections are serious business - SERIOUS business. They are arguably the last bulwark that can prevent a dissatisfied populace from feeling the need to resort to force of arms to assert their will (which I think we can all agree is something we'd like to avoid).
    International news is Full of examples of the outcomes of other options - and they are not good.
    It follows that accurately predicting the outcome of such contests is likewise serious business.

    The cost, and potential for monetary profit, present in the "election futures" market is a beneficial component of their function, being necessary to ensure seriousness of commitment to position of participants. If you have to pay to play, you will not play lightly. Likewise, the potential for monetary gain encourages borad paerticipation. LIKE ANY OTHER MARKET.

    There is also the issue of appearances.
    Given the degree of political polarization in the US these days, and the degree of skepticism concerning the validity of outcomes in recent years, an uncharitable observer might be forgiven from concluding that shutting down election prediction markets was part of an attempt to hide a planned fraud in those elections.
    NOT a good look.

    So let the market be the market. There seem to already be all sorts of other constraints in place on the practice; let them be enough.


    Sincerely Yours,



    Jasper Merendino

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