Comment on CFTC-2026-0331, CFTC-2026-0331-0001, Julian, Gill

I am an investor in semiconductors and AI infrastructure. My comment addresses Question 10. Capital allocation in technical markets depends on price discovery. The questions that matter most to my work when a fabrication node will hit a given yield, when a frontier model will cross a capability threshold, when an export-control regime will shift are exactly the questions for which no public pricing exists today. Commercial event-contract platforms have not listed them and structurally will not. Volume economics: a market on a specific fab's process yield draws a few hundred informed traders globally, against millions for sports and elections, so retail-funded venues route capital toward retail-legible questions. Resolution cost: technical questions require expert adjudication and often turn on contested or non-public information, exposing a commercial venue to legal and reputational risk its book cannot absorb. Adverse selection: thin technical markets disproportionately attract informed flow, market makers widen spreads, and the price-discovery function the contract is meant to serve collapses. None of this is a failure of the commercial platforms; it is rational behavior given their cost structure. Section 3(a) names price discovery and the dissemination of pricing information as core purposes of the Act. The markets that would generate the highest social value under that standard are precisely the ones the commercial submarket is not built to list. Nonprofit research venues operating under academic adjudication, subsidized liquidity, and published methodology can absorb the resolution and liquidity costs that defeat a commercial book, because they are not running a profit-and-loss on the order book. The IEM and PredictIt no-action letters reflect a Commission that already understood this, and the public pricing that came out of those programs has been cited in academic and policy work for thirty years. I have benefited from that data as a downstream consumer without ever opening an account. Treating prediction markets as a single category collapses the case. The commercial submarket and the nonprofit research submarket have different cost structures, different audiences, and different social functions, and the Section 3(a) analysis should reflect that. The Commission should codify a clear pathway for nonprofit research markets rather than continue to administer it through discretionary staff letters.