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Comment for Proposed Rule 91 FR 12516

  • From: christian r webber
    Organization(s):

    Comment No: 115214
    Date: 4/25/2026

    Comment Text:

    prediction market's are fundamentally at odds with a productive and good society.
    they encourage massive amounts of fraudulent behavior and incentivize insider trading, offering a venue for legitimizing gambling as well.

    the system as it exists is marketed as a "prediction market" when in actuality the outcomes are not representative of legitimate means of analysis, the data sets are heavily skewed and can not work as an accurate method of prediction.

    for an example, if a person of power is in a position where they are privy to certain information and can bet on any certain outcome, whatever the person bets on will inform how they intend to act. this is a very obvious mechanism for abuse and societal harm.

    if a bet sprouts up for "when will a forest fire happen next" or "when will the united states go to war with Iran" a person could place money on a certain outcome and then work to achieve whatever results they have a monetary incentive for, making the "prediction" aspect to be a false claim.

    it is of additional concern that both Polymarket and Kalshi have people on their bankroll that serve in a "market maker" role where they act as a counter weight for incentivization of certain bets. these individuals are privy to additional data and information, providing an uneven environment where bets are not legitimate.

    as for another example of unfair use, both of these sites utilize UMA tokens to decide uncertain outcomes. when a bet titled "will Zelensky wear a formal suit" was concluded token holders actually decided whether or not the "suit" was considered "formal" or not. this is obviously entirely too arbitrary to be considered a "Prediction market" result, or be considered anything other than just gambling.

    it's a similar to how a casino operates, but is more insidious, as half of the gamblers are in fact on the casino's payroll, and people can debate the cards at play if they have enough UMA tokens. if a business operated in such a fashion it would be deemed as corrupt, but due to the digital legitimization these "prediction market" apps are seen as a cornerstone of future market development and a brand new liberatory mechanism for personal wealth. despite being civilization ruining methods of leeching money based on illegitimate means.

    the impacts of this unethical practice should be self evident, as I have demonstrated in this comment
    I sincerely hope my insight will be considered, as I deeply care about this issue and how it impacts my fellow countrymen.

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