Comment on CFTC-2026-0331, CFTC-2026-0331-0001, Adam, Barrick

Summary: Adam Barrick of Kalshi supports the Commission's consideration of player-performance event contracts as self-certifiable derivatives under Part 40. He argues that these contracts serve a significant commercial hedging purpose for the sports economy, provide superior price discovery compared to sportsbooks, and can be effectively regulated using existing CFTC surveillance frameworks.