Comment Text:
I'd like to make the case that the restriction and classification of PredictIt and its ilk as "gaming" is reductive, and restrictions based on it are unintentionally damaging to the public interest.
The definition of "gaming" used currently simply says a prediction market for political outcomes IS "gaming", and a stock market for business outcomes IS NOT "gaming". No explanation is given as to the essential qualities that allow one to earn the classification while the other gets excluded.
Both allow individuals to predict the success or failure of a venture at a given point, and exchange representations of those predictions when they differ. Both involve the potential of financial gain from a correct prediction, in order to incentivize actual investigation and better align the overall outcome with the reality of the situation that is being predicted. There are minor differences (IPO's, dividends, etc), but none of these support a strong case that a stock market is not "gaming" while a prediction market is. We are left with the circular definition that "The CFTC classification of gaming is the things that the CFTC classifies as gaming", rather than something workable and consistent.
Given this arbitrary classification, undeserving and publicly valuable enterprises are potentially getting shut down. This attempt to protect the public interest ironically damages the public interest. I can use PredictIt as an example.
PredictIt's goal is to gather data that can be used in research, which is more accurately reflective of individual behavior in various situations than the alternatives, such as polls. Having participants have a stake in the proceedings aligns their actions more with their behavior in other real-life situations, vs. alternatives such as polls. Polls are done from memory and often contain inaccuracies due to the lack of stakes involved in answering, whereas prediction markets provide both the real-time decision data and the stakes to make it realistic. Researchers who want to better understand the impact of decision making from news consumption, the impact of hard data vs speculation, and many other things get access to this data which they can't get otherwise. PredictIt keeps only enough money to fund the technology for gathering data.
As for the participants, the many restrictions on the site make it unappealing for gamblers only seeking to gamble, vs. the alternatives. Positions are limited to $850. There are no 'dark patterns' seeking to re-engage participants to participate more. The markets take weeks, months, and years to play out -- which, combined with the low investment cap, make it both unappealing as a meaningful wealth generator AND unappealing as a quick dopamine rush that gambling addicts chase. Anyone looking for either of these things have far better options -- and the people that remain enjoy using the site for what it is, and for how it's helping. No one is being taken advantage of, and no one is being 'saved' by restricting this interaction.
Overall, I hope you reconsider this decision -- it is made with good intentions, but will have negative consequences regardless. I appreciate your time.
