Comment on CFTC-2026-1189, CFTC-2026-1189-0001, Johnny Ray, Work Jr.

I write in support of the Commission's proposed public-interest framework for sports event contracts (RIN 3038-AF65), and respectfully urge two clarifications that would make the rule more administrable without chilling legitimate, well-functioning markets. 1. The permitted category is sound. Contracts on aggregate sports outcomes -- final scores, point differentials, win-loss results, tournament advancement, and statistical performance -- supported by objective, verifiable data and integrity infrastructure settle on public, objectively verifiable results rather than contestable judgment calls; they aggregate dispersed information into a price (the price-discovery and information-aggregation utility the Commission identifies); and they are administrable by objective criteria. I support retaining this category and the "objective, verifiable data and integrity infrastructure" standard as the touchstone. 2. Draw the prohibition at the settlement basis, not at pricing inputs. I support excluding contracts that settle on a player injury or an officiating decision; those present the integrity and limited-control concerns the Commission describes. But I ask the Commission to state expressly -- in Appendix F or the adopting release -- that the prohibition reaches the settlement basis of a contract (the event on which it pays out), not the informational inputs used to price a permitted contract. Injury reports, weather, and officiating assignments are public, objective data routinely used to price ordinary win-loss, point-spread, total, and statistical-performance contracts. A participant who marks down a permitted moneyline contract because a starting pitcher was scratched is using public information, not trading an "injury contract." Construing the prohibition to reach such inputs would be unadministrable (the Commission cannot police the private analytics behind a price), would degrade the price discovery the rule prizes, and would invite arbitrary line-drawing, since virtually every sports price already reflects injury and personnel information. Recommendation: state expressly that using injury, weather, or officiating information to price a permitted contract does not render it an "injury" or "officiating" contract. 3. Define "limited-control or discrete outcomes" precisely. Left undefined, that phrase risks capturing contracts the proposal permits -- e.g., a full-game or season-long aggregate statistical contract (a player's total points; a pitcher's total strikeouts), which falls within the permitted "statistical performance" category yet is, at some level of abstraction, a single "outcome." I urge the Commission to define the prohibited set as contracts that combine: (a) minimal aggregation -- a single, discrete in-game event (one pitch's ball-or-strike, the next play type, a single officiating call), as distinct from an outcome aggregated across a full game or season; (b) low objective verifiability or heavy dependence on judgment; and (c) heightened manipulation susceptibility, where one participant or official can materially influence the discrete event. Contracts that aggregate over a full game or season, settle on objective and verifiable data, and are not readily manipulable should be placed expressly outside this prohibition. Tying the definition to aggregation window, objective verifiability, and manipulation resistance keeps the rule self-executing for exchanges and consistent with the Commission's market-integrity factor. Refined this way, the permitted/prohibited boundary becomes administrable and largely self-classifying: a designated contract market can sort contracts by settlement basis and aggregation window without policing pricing inputs or parsing undefined terms. This preserves the utility of legitimate sports event contracts, excludes the genuinely problematic micro-event, injury-settled, and officiating-settled contracts, and gives participants clear, predictable rules -- serving each of the three public-interest factors the Commission proposes to weigh. Thank you for the opportunity to comment. Respectfully submitted, Johnny Ray Work Jr. Pennsylvania