Comment on CFTC-2026-0331, CFTC-2026-0331-0001, Underdog Sports Holdings, Inc.

Summary: Underdog Sports Holdings, Inc. supports the CFTC's consideration of a new rulemaking framework for prediction markets, advocating for a principles-based approach that balances innovation with market integrity and consumer protection. The company argues that sports event contracts are not inherently susceptible to manipulation and suggests that the CFTC should provide clear guidance on settlement criteria, data sourcing, and the definition of "gaming" to foster a regulated domestic market.