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Comment for Proposed Rule 89 FR 48968

  • From: Lewis Lieberman
    Organization(s):
    None

    Comment No: 73917
    Date: 7/6/2024

    Comment Text:

    The commission's proposed rule to effectively ban political event contracts is ill advised. It includes an overly broad interpretation of the term "Gaming" regarding such contracts. In fact, they are more analogous to trading in securities or commodities than to sporting events or games of chance.

    Participation in these contracts leads to widespread self education in the underlying issues which should be viewed as a public good. Successful participation requires the ability to make informed decisions by processing information from multiple sources and ultimately making decisions which, if correct, can lead to financial gain. Additionally, the ability to trade safely on election outcomes enables the individual citizen to protect their own financial interests by hedging on expected results
    which would otherwise have negative impacts.

    The argument that political event contracts somehow could be used to undermine election security is baseless and contradicted by all prior experience with such markets.

    Respectfully, the Commission should also seriously consider whether the recent Supreme Court decision in Loper Bright Enterprises v. Raimondo which overturned the Chevron doctrine is relevant to this attempt of what can reasonably be viewed as regulatory overreach.

    All things being equal, the freedom inherent in our democratic society would best be served by allowing participation in political event contracts. Elections have consequences and citizens should be permitted to trade on their outcomes as they see fit.

    Sincerely,
    Lewis Lieberman

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