Comment Text:
With much appreciation for the work of the CFTC, I write this note in support of a position that election markets, and "Predict It," in particular, are not gaming.
Opinion markets and purchases of options on opinion resolution (i.e., elections) are not games in which each purchase of an option is responded by an opponent's counter action. In fact, the opinion markets are "valuation" markets in which each of the binary positions in the market has a higher or lower value as opinions change within a changing national social and economic context. The values change in response to the participants' perceptions of the outcome likelihood of important election events.
Unlike gambling on repeated rounds of sports events, the election markets provide economic signals about important community-determined future social outcomes. Because the signals are developed from the opinion holders' willingness to pay to support their positions with money, the signals from the prices are currently more reliable than sample-based polls in which there is no monetary incentive for poll respondents to be truthful.
I support any regulation that makes any market more complete and more perfect and improves the reliability of information that is reflected in it. I support any regulation that makes more fair transaction and settlement costs in any market.
Thank you very much.