Comment on CFTC-2026-1189, CFTC-2026-1189-0001, David, Rothschild

Summary: Dr. David M. Rothschild, an academic researcher, opposes the proposed rule's category-based framework for prediction markets, arguing instead for a design-and-purpose-based approach. He contends that the current proposal fails to distinguish between high-information markets (like elections) and low-information "gaming" markets (like sports), and urges the Commission to codify a distinct regulatory pathway for nonprofit and smaller information-oriented markets.