Comment Text:
I am an Uber driver. I have a GED and no financial background. I am submitting this comment because I lost $8,000 on Kalshi — money I earned driving strangers around at 2am — and because I think the Commission is asking a lot of complicated legal questions when the answer in front of them is straightforward. I will try to address the Commission's specific questions as plainly as I can.
On Whether These Contracts Serve a Public Interest (Questions 7–11)
The Commission asks what public interest event contracts serve — specifically whether they enable price discovery, risk management, or hedging.
I did not hedge anything on Kalshi. I have nothing to hedge. I drive a car for a living. Nobody on Kalshi is hedging. The people I know who used it — mostly younger guys I talked to during rides — were not managing commercial risk. They were gambling. They were doing exactly what people do on sports betting apps, except Kalshi told them they were being sophisticated instead of reckless.
The Commission's own framework says derivative markets serve the public by helping people manage price risk and discover prices. Ask Kalshi to identify a single retail participant who used its platform to manage a genuine commercial exposure. Ask them to show the Commission what risk was transferred and to whom. They cannot do it — because the product is not built for that. It is built to get people like me to deposit money on whether a politician gets indicted.
That is not a public interest. That is a business interest. The Commission should not confuse the two.
On Gaming and the Public Interest Determination (Question 19)
The Commission asks what factors define "gaming" and whether prediction market contracts fall within it.
I will save the Commission the legal analysis. When I put $200 on whether the Fed raises rates by a specific amount, I am not an economist with a view on monetary policy I am trying to monetize. I am a guy who read something on his phone between rides and felt a rush placing the bet. That rush — that feeling — is identical to what I feel placing a sports bet. The interface is identical. The psychology is identical. The outcome is identical.
The Commission asks whether gaming encompasses activities with "an element of chance." Every contract on Kalshi has an element of chance for the retail participant, because retail participants do not have superior information, institutional resources, or analytical tools. We have our phones and our gut feelings. That is gambling.
The Commission also asks, in question 19(d), whether it matters that prediction market users tend to be younger. It matters enormously. Every person I have given a ride to who mentioned Kalshi has been under 30. Several were college students. The platform finds young people where they already are — on social media — and uses the language of intelligence and analysis to make gambling feel like self-improvement. That is predatory targeting of the most vulnerable gambling demographic, and it should disqualify Kalshi from operating under a public interest justification.
On Manipulation and Inside Information (Questions 29–32)
The Commission asks whether prediction markets are susceptible to manipulation and how inside information affects market integrity.
From where I sit, the manipulation question has an obvious answer. When contracts exist on whether a specific politician will be arrested, indicted, or win an election, the people best positioned to trade on those contracts are the people closest to those outcomes — campaign insiders, government staff, prosecutors, lobbyists. These people have information the rest of us do not have. When they trade on that information, they take money from people like me who are trading on news articles and instinct.
The Commission acknowledges in questions 31 and 32 that federal employees are legally prohibited from trading on nonpublic government information. The Commission has brought no enforcement actions in this space. That means the prohibition is not functioning. A law that is not enforced is not a protection — it is a formality. And a market built on the systematic information advantage of political insiders over retail participants is not a fair market. It is a mechanism for transferring money from ordinary people to connected ones.
On Core Principle 2 — Abusive Practices and Impartial Access (Question 2a)
The Commission asks what aspects of prediction markets affect impartial access and create risks of abusive trading.
Kalshi's access is impartial in the legal sense — anyone can sign up. But impartial access to a rigged game is not meaningful fairness. When institutional participants, politically connected traders, and sophisticated algorithmic accounts share a market with an Uber driver who found the app on Instagram, the access is formally equal and functionally predatory.
The Commission's core principle requires DCMs to prohibit abusive trade practices. Designing an app to maximize deposit frequency, eliminate friction from the deposit process, send push notifications during high-emotion news events, and offer referral bonuses calibrated to recruit young users — that is an abusive practice. It is not a trading practice, but it is the practice that determines how retail participants end up in these markets and how much damage they sustain. The Commission should expand its reading of abusive practices to encompass the onboarding and retention mechanics of platforms targeting retail gambling customers.
On Financial Integrity and Margin (Question 2f)
The Commission asks whether prediction markets should be permitted to offer trading on margin.
No. Absolutely not. The Commission should prohibit margin trading on event contracts for retail participants without exception.
Binary contracts already function psychologically like leveraged products — a near-miss loss triggers the same recovery-seeking behavior that drives compulsive gambling regardless of whether margin is involved. Introducing actual leverage into this environment would be catastrophic for retail participants. The losses I sustained were from capital I actually had. I cannot imagine what would have happened if Kalshi had offered to let me bet more than I owned. Some people would take that offer. Some of those people would not recover financially.
What the Commission Should Do
The Commission has asked detailed, sophisticated questions. I have tried to answer them plainly. Here is my plain conclusion:
Kalshi is a gambling company with a regulatory license it obtained by calling itself something else. It targets young, non-wealthy people through social media. It has no responsible gambling infrastructure. Its political contracts are structurally advantageous to insiders at the expense of retail participants. It has preempted state consumer protection laws that my state's legislature passed to protect people like me.
The Commission should revoke Kalshi's DCM designation. It should prohibit retail binary event contracts that serve no hedging function. It should ban political event contracts entirely. It should require any prediction market permitted to continue operating to implement deposit limits, loss alerts, self-exclusion, and advertising restrictions equivalent to what Tennessee requires of licensed sports betting operators.
I drove 47 hours last week. I made $623. Eight thousand dollars is a long time behind the wheel. The Commission should make sure no one else loses theirs the way I lost mine.
