July 4th 2008
The Commodity Futures Trading Commission
Three Lafayette Centre
1155 21st Street NW
Washington, DC 20581
U.S.A.

Attention: Office of the Secretariat

RE: “Concept Release on the Appropriate Regulatory Treatment of Event Contracts”

To Whom it May Concern:

It is an honour for me as Chief Executive Officer of Intrade the Prediction Market Limited (“Intrade”) to provide price discovery information on thousands of event markets free of charge to notable institutions such as yourselves at the U.S. Commodity Futures Trading Commission, the U.S. Navy, the Federal Reserve Banks of New York, Richmond, and Chicago, the European Central Bank, the Bank of Japan, the American Enterprise Institute – Brookings Joint Centre, CATO Institute, and the Bank of England. We have similarly supplied our price discovery event market information to political organisations, students and staff at every Ivy League College, and students and staff at over 50 universities worldwide.

We estimate that over 300 global media businesses such as The New York Times, The Wall Street Journal, The Washington Post, The Financial Times, The Los Angles Times, Chicago Tribune, Economist, Bloomberg, Reuters, Forbes, Time, Fortune, CNN, CNBC, Fox, ABC and others have used Intrade event market information.

Investment firms on Wall Street, and the other major financial centres of the world, have solicited and been provided with Intrade price discovery event market information. The above lists are not exhaustive.

Further, Intrade provides free real-time transparent price discovery event market information to millions of people from the general public. While Intrade serves a global community and has registered members from 162 countries, our 82,000 plus membership are predominantly resident in the United States. The predictive probability information on event markets that we supply to the general public is both intuitive and readily and rapidly assimilated without the necessity for paid subscriptions or a financial education.

Intrade has been transparent and industrious, as have others, in nurturing the development of the event market industry. Intrade as a profit-maximizing business does of course expect to significantly benefit from its dedicated employment. However the benefits to society at large will be equivalently great from Intrade’s focus on event markets.

While U.S. institutions and society benefit from Intrade’s services it is perversely unclear as to whether Intrade, and indeed myself, are considered persona gratis by the United States. However, we are more optimistic than ever that Intrade as the de facto leader in the event market industry sector will soon have the ability to stand on a firm, transparent and appropriate regulatory footing thanks to the process that the CFTC has accelerated through their request for comments on how to regulate event markets.

Not since the Industrial Revolution have the risks and their commensurate opportunities of dealing with great uncertainty and rapid change that we all face been so high. Much of this change and uncertainty is technology driven, with most countries, organizations and households accepting, in theory at least, that they must change.

The recent implosion of credit markets is just one example of the great uncertainty and potential for events impacting citizens of the United States and farther afield.

To adapt to a changing world in an orderly and optimal manner requires access to information, robust decision-making processes and the courage and determination to grasp the opportunities that a dynamic world offers. The CFTC and indeed the United States itself has access to the information, the decisionmaking expertise, and a historical track record of determination and accomplishment.

But the relentless change that we all face will be best dealt with if we have the best information, in real time, to reduce uncertainty, risk and stress. Event market information can and has increased the quality and timeliness of decision-making. Event markets can act as a democratic mechanism that gives voice to the broadest range of event stakeholders and, in so doing, aggregates a peerless information set. By encouraging the aggregation, distribution, validation and appropriate use of the best event market information, society will benefit even more than it does today from event markets. To do otherwise than to encourage event market development would be a societal travesty.

The dynamic nature of the world that we live in, where the pace and systematic impact of change seem to be increasing, will be greatly aided if event markets are given a certain regulatory footing in the United States and other jurisdictions. This, coupled with the fact that markets excel in aggregating information and estimating the value of a product or the likelihood of an event occurring, testifies to the logic that the price discovery that event markets produce should now be encouraged by the CFTC.

The CFTC by clarifying the status of event markets now will be of great service to Americans. In this regard the CFTC has an important opportunity and one that the CFTC seem very positively biased to grasp in light of its statements, such as…
- The CFTC state on their website that they have “An Important Mission in the Ever-Changing World of Finance.”
- “The CFTC assures the economic utility of the futures markets by encouraging their competitiveness and efficiency.”
- “The CFTC is also mandated to enable futures markets to serve the important function of providing a means for price discovery and offsetting price risk.”

CFTC Acting Chairman Walt Lukken, when announcing the execution of a memorandum of understanding with the SEC on March 11, 2008, stated: “The regulatory structure that oversees the U.S. financial markets embrace innovation, growth and competition in the global marketplace, without compromising market integrity, customer protection and the public good.”

The above statements, in addition to the Concept Release by the CFTC, are very encouraging. It is specifically this price discovery and risk management mandate that justify the CFTC’s embrace of event markets, should justification be needed.

Intrade has listed 211,607 individual event markets and aggregated and distributed predictive event market information on subjects such as Arctic Oil Drilling, Climate Change, Commodities, Company Earnings, Constitutional Referenda, Currencies, Disease Outbreaks, Earthquakes, Economic Numbers, Entertainment Awards and Earnings, Indices, Euro Adoption, Federal Reserve Announcements, Gas Prices, Gasoline Tax, Geo Political Events, Homeland Security in the U.S., Mergers & Acquisitions, Social Security Reform and U.S. Taxes. This list is far from exhaustive.

No other platform has listed more event markets than Intrade. To the best of our knowledge and belief the event market leadership position that is often ascribed to Intrade is wholly justified from a review of the breadth of the event markets listed and information we have aggregated and distributed. Information, as noted above, that is used by governmental agencies, businesses, academics, and the general public to reduce uncertainty and in so doing increase the speed and quality of decisions being made.

While the obvious benefits to the general public in terms of price discovery and decision-making of some Intrade event markets will be more obvious than others, we can make robust arguments that all have the potential to serve the dual purpose of price discovery and a mechanism for offsetting price risk.

The CFTC by clarifying its position on event markets will give all event market stakeholders valuable direction on market and participant eligibility. Whether used at the federal government level or by the individual citizen, event markets provide a magnificent opportunity to use price discovery information in managing economic risk. Here are just a few examples from the 211,607 event markets we have listed.

Intrade has listed markets on the probability of the Homeland Security alert level being above or below a certain level at a certain date. “The United States spends roughly $100 billion per year on homeland security” according to the White House. The costs of migrating from a threat level of “Guarded” to a threat level of “Elevated” have very significant costs for the government, business, and society. By utilizing event market price discovery information on the probability that the alert level will be at a certain threshold on a given date, the economic consequences of the threat level can be managed in a more insightful way.

Jason Ruspini has suggested markets to Intrade on whether the marginal personal income tax rate for single U.S. filers will be equal to or greater than a range of specified percentages for tax years 2009, 2010 and 2011. Having spoken directly to a number of tax paying citizens from the United States, the transparency of this information undoubtedly serves a public good. Is there a Unites States resident taxpayer who will read this comment who is not interested in the taxes she or he will pay next year?

On a more macro level, Intrade has listed a market on whether the cold fusion experiment of Dr. Yoshiaki Arata will be replicated in a peer-reviewed scientific journal before 31 December 2009. The possible impact of such a development to our energy needs little hyperbolae. The fact that President Bush requested $25 billion for the U.S. Department of Energy’s 2009 Budget speaks to the importance of maximum transparency in such matters. It may also be interesting to note that $493 million of the $25 billion was allocated to Fusion Energy Services. Does transparency to such price discovery information serve positively the United States and others? Absolutely!

Professor Koleman Strumpf suggested that Intrade list a market on whether Blu-Ray Disc sales will outnumber HD-DVD disc sales in the United States in 2008. If an organisation’s employees or profits are potentially influenced by the outcome of this event, as were Toshiba’s, the main supporter of HDDVD, then access to such information is both valuable and gives opportunity for welfare maximisation.

Intrade has also listed, at the request of University of Westminster Business School, markets on whether the number of violent crimes committed in 2010 will be lower than those committed in 2007. Intrade has additionally listed at the request of a United States resident member of our platform a market on the impact of U.S. Government debt if a non-Democrat is elected president of the United States in 2008.

Professor Eric Zitzewitz, Professor Robin Hanson, Professor Justin Wolfers and others at the forefront of event market academia have all suggested event markets to Intrade in the past that have been listed and which provided event market information both for academic study and business and general public use.

Imagine if you were a resident of a state such as Florida that is frequently exposed to severe storms and how crucial information on the likelihood of a storm hitting your state can be if your business, family and friends are likely to be impacted by such an occurrence. Intrade lists event markets on such
eventualities.

The event markets listed on Intrade provide price discovery information on whether an earthquake measuring 9.0 or more on the Richter Scale will happen anywhere in the world in 2008; whether Avian Flu H5N1 is confirmed in the United States in 2008; whether the U.S. carries out an overt attack on North Korea; or even whether Robert Mugabe departs his presidency in 2008. These significant events are highly relevant to millions of people in the United States and elsewhere.

President Bush stated in an address on global climate change that: “This is a challenge that requires a 100 percent effort; ours, and the rest of the world’s.” It seems to us impossible to make a “100 percent effort” to address the challenge of climate change without using event markets to aggregate information, such as that provided by Intrade’s market on whether 2008 will be one of the warmest years ever recorded.

All of the markets cited above give information on the probability of the event occurring. Some of the information aggregated and distributed by Intrade has been more predictive than other. The predictive accuracy of Intrade’s event markets and event markets generally have been cited and studied extensively by academics and others including, but not limited to Professor Robin Hanson, Professor Charles Noussair, Professor David Paton, Professor Leighton Vaughan Williams, Dr. David Pennock, Professor Eric Zitzewitz, Professor Mark Perry, Professor Erik Snowberg, Professor Marco Ottaviani, Professor Justin Wolfers, Professor Koleman Strumpf, and Professor Paul Tetlock.

Nearly all leading academics, not known for their attraction to unanimity, have publicly supported event markets. A great majority of these academics have been supplied with Intrade market data in the past, a service that Intrade intends to continue, for all study leads to an increase in transparency and understanding of event markets. It seems that the leading event market academics make no distinction between the benefits derived from academic owned markets like Iowa Electronic Markets and commercial market platforms like Intrade.

Yet many academics, with some notable exceptions, do temper their policy prescription to suggest a “safe harbor” for academic sites where research might be more generally available. As noted above Intrade has gladly supplied its event market data, typically free of charge to most of the leading prediction market academics and their students, and we are committed to encouraging the future study of event markets by continuing to supply our event market data free of charge or at very deep discounts. The academics that study event markets do a great service in developing our understanding of the strengths and weaknesses of event markets. Some commentators suggest that market liquidity and breadth typically benefit all event market stakeholders. Thus far commercial platforms like Intrade seem to be providing the greatest depth and breadth in event markets.

As Intrade has been a staunch supporter of event market academic study, and supplies greater depth and liquidity in its event markets than any other platform, it seems strange not to be a preferred purveyor. Perhaps the predominant reason many academics have held back from advocating and treating all event markets alike is a sense that initiatives to clarify or unwind the legislation restraining the optimal development of event markets is unlikely to be achievable. It seems many academics and commentators suggest a slow bureaucratic and pragmatic caution rather than focus on the optimal result. While the optimal result may be more challenging to achieve, for consistency, for better price discovery for the benefit of all, as well as for the development of Intrade, we encourage CFTC to apply common goals, objectives and standards for all participants.

While some evidence and event markets have highlighted that event markets do not always provide robust predictive information, the preponderance of the research suggests that event markets have both the ability and track record of providing the best available information upon which decisions may be based or optimised. Of course the uncertain regulatory status of event markets constrains the development of liquidity, price discovery and by logical extension societal benefits.

Intrade has received testimonials from numerous U.S. regulated businesses and private citizens which state they would like to trade on certain event markets but are unable due to the regulatory uncertainty. Therefore, unless and until event markets are given a certain status they will not develop to their full potential.

Based on the above and comments by many others, some of whom have been mentioned by name in this comment, the price discovery mandate that the CFTC has can only be served if event markets are embraced.

In terms of offsetting price risk and the opportunity for hedging, the overwhelming majority of markets listed by Intrade can easily be seen to have underlying economic implications and risks. For example, U.S. tax rate changes, a negative geopolitical event, an increase in the threat level to homeland security and the associated costs of a higher threat level, or indeed Social Security reform all have massive economic justifications across society.

As with the CFTC’s price discovery mandate, it is impossible for us to imagine how risks can be optimally assessed and managed without the status of event markets being clarified.

The CFTC are also sensitive to retaining the competitiveness of futures markets and retaining “competition in the global marketplace”. There has been much written about the United States losing its edge in global financial markets. Often cited is that burdensome and inflexible regulations, most notably the Sarbanes-Oxley legislation passed by Congress in 2002, are driving business to London, Hong Kong, Frankfurt and elsewhere. In this regard, the CFTC has an opportunity to be a world first and embrace event markets. In so doing the CFTC will ensure the United States’ leadership position is encouraged for the important and growing event market industry.

The greatest challenge in bringing about an appropriate and successful embrace of event markets by the CFTC is unlikely to be identifying and agreeing that the public good will be served, or that risks may be better managed. The challenge for the CFTC may well be the uncertainties relating to legal and jurisdiction issues. In these matters there are experts far better versed than Intrade to opine.

The financial events of the last six months in which virtually the entire world financial system stopped functioning to a greater or lesser extent has highlighted what can happen when many of the world’s largest financial institutions make concurrent similar mistakes. Such systemic contagion has led commentators to suggest a more fundamental approach to how and what we regulate. Where event markets are concerned we are hopeful that this is the case and that the level of regulation is such that the evolving stage of the event market industry is not stifled.

We are proud to be at the forefront of the development of the event market industry. We are determined to continue providing the best information on relevant event markets to the widest audience. We wish to solidify our regulatory position in the U.S. and elsewhere. We strongly encourage the CFTC to clarify the situation with regard to event markets for the benefit of all, even if there are costs to Intrade. We are highly optimistic that the CFTC will grasp this opportunity to benefit all society and we wish to serve our own most important role in an industry niche that we have been privileged to help shape.

Respectfully Submitted on behalf of the entire Intrade Team by
John Delaney
Chief Executive Officer

CC to Fax 202.418.5521 and e-mail: secretary@cftc.gov.

1. “Intrade … isn’t just an entertaining Web site. It is the latest iteration of one of the most important economic developments of modern times.” David Leonhardt, Economics Reporter, The New York Times, February 14, 2007

2. Costs of regulation are high in the U.S., “that’s a key reason the leading commercial prediction market, Intrade, is based in Ireland” Prof Paul Tetlock, Wall Street Journal, May 11th 2007

3. “On Dec. 11, 2003, Intrade’s contract on Saddam Hussein’s capture suddenly began to move. … Two days later, Saddam was in custody.” Bill Saporito, Time Magazine, October 24, 2005

4. “At FORTUNE we often write about the latest hot company, but it’s rare that we get a chance to introduce you to an entirely new market… Intrade is the only efficient market system around for investing in, well, almost anything” Andy Serwer, Managing Editor, Fortune, August 8, 2005

5. 78% of traffic to Intrade.com in the period 1 January to 30 June was from the U.S.

6. “Intrade futures market ~ the greatest time-saving invention of this century.” John Tierney The New York Times

7. The Uncertainty Stress Scale: its development and psychometric properties. Can J Nurs Res. 1994 Fall;26(3):15-30, PMID: 7889446

8. As of June 30 2008

9. For many people, Intrade is the king of the prediction markets.” Stephen Dubner, Freakonomics, The New York Times July 5 2007

10. http://www.whitehouse.gov/homeland/book/sect5.pdf.

11. http://feedroom.businessweek.com/?fr_story=5a3aa8086dbd52b35ae21c7f5abe94f85fa0a8ab&rf=sitemap.

12. http://www.energy.gov/news/5920.htm

13. “Want straight answers on what will happen in politics and current events? Answers without partisan bias or wishful thinking? You can’t do much better than the prices at Intrade.” Professor Robin Hanson, Professor of Economics, George Mason University

14. “My forecast? Prediction markets will become ever more important to business and public policy. And Intrade are running the most interesting markets around.” Professor Justin Wolfers

15. http://www.whitehouse.gov/news/releases/2001/06/20010611-2.html

16. “Analysts can debate about a recession as much as they want, but talk is cheap. It’s great to have [Intrade] futures trade where people put money behind their beliefs!” Professor Mark J. Perry, University of Michigan-Flint

17. http://www.international-economy.com/TIE_Sp07_Baker.pdf and http://knowledge.emory.edu/article.cfm?articleid=1015

18. “Regulatory Underkill,” Arthur Levitt Jr., Wall Street Journal, March 21, 2008

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NEXT: More from John Delaney about regulations

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#1. The Commodity Futures Trading Commission (CFTC), the federal regulatory agency that oversees futures market activity, should establish safe-harbor rules for selected small-stakes markets. One limited safe harbor is the no-action letter, in which the CFTC market oversight staff confirms in writing that it will not recommend enforcement action if the recipient acts in specified ways. The only prediction market to receive a no-action letter (in 1992) is the Iowa Electronic Markets, which is run by professors at the University of Iowa and which initially focused on presidential elections. Although such no-action letters reduce the chances of legal action under other state and federal laws, they may not be adequate. We would therefore urge the CFTC to explore other approaches to ensuring safe harbors, for example, formal rules or guidance approved by the commission. We suggest that three types of entities be eligible for safe harbor treatment. The first would be not-for-profit research institutions, including universities, colleges and think tanks wishing to operate exchanges similar to the Iowa Electronic Markets. The second would be government agencies seeking to do research similar to that of nongovernmental research institutions. The third group would consist of private businesses and not-for-profits that are not primarily engaged in research, which would only be allowed to operate internal prediction markets with their employees or contractors. In all cases, markets would be limited to small-stakes contracts. Although the definition of small stakes is somewhat arbitrary, we use the term to mean an exchange in which the total amount of capital deposited by any one participant may not exceed some modest sum, perhaps something like $2,000 per year. The exchanges themselves would be not-for-profit but would be allowed to charge modest fees to recoup administrative and regulatory costs. Brokers and paid advisers would be barred, reducing the risks that contracts would be sold to inappropriate or vulnerable customers or that customers would be charged fees above the amounts needed to maintain the markets. Exchanges would be self-regulated, leaving them with the responsibility to make reasonable efforts to keep markets free from fraud and manipulation. For its part, the CFTC should allow contracts that price any economically meaningful event. This definition could allow for contracts on political events, environmental risks, or economic indicators, such as those offered by the Iowa Electronic Markets, but would presumably not include contracts on the outcomes of sports events.

The contracts qualifying under this safe harbor would also create opportunities for more efficient risk allocation. Although the small-stakes nature of these markets would necessarily limit their usefulness for hedging risk, they could serve as proofs of concept for larger-scale markets that could be developed under alternative regulatory arrangements. The CFTC should allow researchers to experiment with several aspects of prediction markets – fee structures, incentives against manipulation, liquidity requirements and the like – with the goal of improving their design. Prediction markets are in an early stage, and if their promise is to be realized, researchers should be given flexibility to learn what kinds of design are most likely to produce accurate predictions. Of course, exchanges would need to inform their customers so that they are aware of the risks and benefits of participating in these markets.

#2. Congress should support the CFTC’s efforts to develop prediction markets. To the extent that the CFTC incurs costs in promoting innovation, Congress should provide the necessary funding. More fundamentally, Congress should explore alternative ways of securing a legal framework for prediction markets if the CFTC’s existing authority proves inadequate. In particular, Congress should specify that a no-action letter, or similar mechanism, preempts overlapping state and federal anti-gambling laws. Because Congress did not intend the CFTC to regulate gambling, it is important to design new regulations so that socially valuable prediction markets easily qualify for the safe harbor but gambling markets do not.

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UPDATE: A great rebuttal here…

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THE MIDAS ORACLE TAKES:

- CALL TO ACTION: Let’s fight so that the CFTC allows the FOR-PROFIT prediction exchanges to deal with “event markets”.

- In the for-profit vs not-for-profit debate, our prediction market luminaries, doctored by Bob, are on the wrong side of the issue.

- COMMENTS TO THE CFTC: What to expect from Tom W. Bell and Jason Ruspini

- A young economist rebuts the American Enterprise Institute.

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BACKGROUND INFO:

- CFTC’s Concept Release on the Appropriate Regulatory Treatment of Event Contracts… notably how they define “event markets”, how they are going to extend their “exemption” to other IEM-like prediction exchanges, and how they framed their questions to the public. Here are the comments sent to the CFTC.

- The Arnold & Porter lawyers explain the meaning of the CFTC’s concept release on “event markets”. — (PDF file)

- The Schulte & Roth & Zabel lawyers’ takes. — (PDF file)

- The Sullivan & Cromwell lawyers’ takes. — (PDF file)

- What Vernon Smith told the CFTC.

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APPENDIX:

Paul Wolfowitz’s profile at the American Enterprise Institute

- How the neo-cons drove the United States of America into the unecessary Iraq war

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Brought to you by Koleman Strumpf (circa November 2007):

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Henry Berg, Microsoft <slides>
Discussant: Robin Hanson (George Mason Department of Economics) <slides>
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Christina Ann LaComb, GE (The Imagination Market; abstract is free, text is gated) <slides>
Discussant: Marco Ottaviani (Kellogg School of Management, Management and Strategy) <slides>
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Dawn Keller, Best Buy (Best Buy’s TAGTRADE Market) <slides>
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Bo Cowgill, Google (Putting Crowd Wisdom to Work) <slides>
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Jim Lavoie, Co-Founder and CEO, Rite-Solutions <slides>
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David Perry, Co-Founder and President, Consensus Point <slides>
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Mat Fogarty, Founder and CEO, Xpree Inc <slides>

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Tom W. Bell, Chapman University School of Law <slides>

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Check that CFM page for updates. And contact me so I can make additions to the list. (I’ll then re-publish that updated list on Midas Oracle.)

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• Michael Abramowicz – Michael B. Abramowicz – (Law School, George Washington University, Washington, D.C., U.S.A.) — Post Archives at Midas Oracle
• Bernd H. Ankenbrand – Bernd Ankenbrand – (Lecturer, Witten/Herdecke University, Germany, E.U.) — Post Archives at Midas Oracle
• James Annan – (Global Environment Modelling Research Program, Frontier Research Center for Global Change, Japan)
• Werner Antweiler – (UBC Election Stock Market, Sauder School of Business, University of British Columbia, Vancouver, Canada)
• Kenneth J. Arrow – Kenneth Arrow – (Economics Department, Stanford University, California, U.S.A.)
• Tom W. Bell – Tom Bell – (Law School, Chapman University, California, U.S.A.) — Post Archives at Midas Oracle
• Joyce E. Berg – Joyce Berg – Profile – (Iowa Electronic Markets, Accounting, Henry B. Tippie College of Business, University of Iowa, Iowa, U.S.A.)
• Richard Borghesi – (Finance, Texas State University at San Marcos, Texas, U.S.A.) — Post Archives at Midas Oracle
• Kay-Yut Chen – (Information Services & Process Innovation Lab, HP Labs, HP, California, U.S.A.)
• Yiling Chen – (Micro-Economic and Social Systems, Yahoo! Research Labs, New York, U.S.A.) — Post Archives at Midas Oracle
• Eric Crampton – (Department of Economics, University of Canterbury, New Zealand) — Post Archives at Midas Oracle
• Ely Dahan – (Marketing, Anderson School, University of California at Los Angeles, Los Angeles, California, U.S.A.)
• Anita Elberse – (Marketing, Harvard Business School, Harvard University, Massachusetts, U.S.A.)
• Leslie R. Fine – Leslie Fine – (Information Dynamics Lab, HP Labs, California, U.S.A.)
• Gary William Flake – Gary W. Flake – Gary Flake – (MicroSoft, U.S.A.)
• Robert Forsythe – (Dean, College of Business Administration, University of South Florida, Florida, U.S.A.) — Previously: (Economics, Iowa Electronic Markets, Henry B. Tippie College of Business, University of Iowa, Iowa, U.S.A.)
• Lance Fortnow – Lance J. Fortnow – (Department of Electrical Engineering and Computer Science, McCormick School of Engineering, Northwestern University, Illinois, U.S.A.)
• Keith Jacks Gamble – Keith Gamble – (Economics (University of California at Berkeley) – California, U.S.A. — Post Archives at Midas Oracle
• Michael Gorham – (IIT Center for Financial Markets, Stuart School of Business, Illinois Institute of Technology, Illinois, U.S.A.) — Previously: (CFTC)
• Thomas S. Gruca – Thomas Gruca – Profile – (Iowa Electronic Markets, Marketing, Henry B. Tippie College of Business, University of Iowa, Iowa, U.S.A.)
• Refet Gurkaynak – (Department of Economics, Bilkent University, Turkey)
• Friedrich August Von Hayek — R.I.P. — The market as an information aggregation tool: The Use of Knowledge in Society —
• Robert W. Hahn – Robert Hahn – (Executive Director, Reg-Markets Center, American Enterprise Institute, Washington, D.C., U.S.A.) — Post Archives at Midas Oracle
• James D. Hamilton – James Hamilton – (Department of Economics, University of California at San Diego – California, U.S.A.) — Post Archives at Midas Oracle
• Robin Hanson – Robin D. Hanson – (Economics, James M. Buchanan Center, George Mason University, Virginia, U.S.A.) — Post Archives at Midas Oracle
• M. Todd Henderson – (Law School, University of Chicago, Chicago, Illinois, U.S.A.)
• Chris Hibbert – (Software Architect, Zocalo Project Manager, California, U.S.A.) — Post Archives at Midas Oracle
• Charles Holt – Charles A. Holt – (Department of Economics, University of Virginia, Virginia, U.S.A.)
• Bernardo A. Huberman – Bernardo Huberman – (Social Computing Lab, HP Labs, California, U.S.A.)
• Frédéric Koessler – (Economics, Centre Nationale de la Recherche Scientifique, France, E.U.)
• Anthony M. Kwasnica – Anthony Kwasnica – (Business Economics, Department of Insurance and Real Estate, Smeal College of Business Administration, Penn State University, Pennsylvania, U.S.A.)
• Nicolas Lambert – (Department of Computer Science, Stanford University, California, U.S.A.)
• John O. Ledyard – John Ledyard – (Economics and and Social Sciences, Division of Humanity and Social Sciences, California Institute of Technology, California, U.S.A.)
• Andrew Leigh – (Economics, Research School of Social Sciences, Australian National University, Australia)
• Steven Levitt – Steve Levitt – Steven D. Levitt – (Economics, Director of the Becker Center on Chicago Price Theory, Graduate School of Business, University of Chicago, Illinois, U.S.A.)
• Saul Levmore – (Law School, University of Chicago, Illinois, U.S.A.)
• Robert E. Litan – Robert Litan – (Vice President for Research and Policy, Kauffman Foundation, Kansas City, Missouri, U.S.A.)
• Thomas W. Malone – Thomas Malone – Tom Malone – (MIT Center for Collective Intelligence, Management, MIT Sloan School of Management, Massachusetts Institute of Technology, Massachusetts, U.S.A.)
• Charles F. Manski – Charles Manski – (College of Arts and Sciences, Norwestern University, Illinois, U.S.A.)
• Adam Meirowitz – (Department of Politics, Princeton University, New Jersey, U.S.A.)
• Paul Milgrom – (Department of Economics, Stanford University, California, U.S.A.)
• Tracy Mullen – (Information Sciences and Technology, Penn State University, Pennsylvania, U.S.A.)
• Forrest Nelson – Profile – (Iowa Electronic Markets, Economics, Henry B. Tippie College of Business, University of Iowa, Iowa, U.S.A.)
• George R. Neumann – George Neumann – Profile – (Iowa Electronic Markets, Economics, Henry B. Tippie College of Business, University of Iowa, Iowa, U.S.A.)
• Ryan Oprea – Profile – (Director of the LEEPS laboratory, Economics, University of California at Santa Cruz, California, U.S.A.)
• Gerhard Ortner – (University of Applied Sciences, Austria, E.U.)
• Marco Ottaviani – (Management and Strategy, Kellogg School of Management, Northwestern University, Illinois, U.S.A.) – Formerly: (Economics Department, London Business School, United Kingdom, E.U.) — Post Archives at Midas Oracle
• David Paton – (Industrial Economics, Business School, Nottingham University, United Kingdom, E.U.)
• David M. Pennock – David Pennock – (Principal Research Scientist, Micro-Economic and Social Systems, Yahoo! Research Labs, New York, U.S.A.) — Post Archives at Midas Oracle
• Charles R. Plott – Charles Plott – (Economics and and Social Sciences, Division of Humanity and Social Sciences, California Institute of Technology, California, U.S.A.)
• David Porter – (Economics and Finance, Chapman University, California, U.S.A.)
• Todd Proebsting – Todd A. Proebsting – (Microsoft & University of Arizona, U.S.A.)
• Russ Ray – (Finance, College of Business, University of Louisville, Kentucky, U.S.A.)
• Daniel Reeves – (Micro-Economic and Social Systems, Yahoo! Research Labs, New York, U.S.A.) — Post Archives at Midas Oracle
• Paul W. Rhode – Paul Rhode – (US Economic History, College of Management, The University of Arizona, Arizona, U.S.A.) – Formerly: (University of North Carolina, North Carolina, U.S.A.)
• Thomas A. Rietz – Thomas Rietz – Profile – (Iowa Electronic Markets, Finance, Henry B. Tippie College of Business, University of Iowa, Iowa, U.S.A.)
• Richard Roll – (University of California at Los Angeles, Los Angeles, California, U.S.A.)
• Thomas W. Ross – Thomas Ross – (UBC Election Stock Market, Sauder School of Business, University of British Columbia, Vancouver, Canada)
• Rahul Sami – (School of Information, University of Michigan, Michigan, U.S.A.)
• Sam L. Savage – Sam Savage – (Consulting Professor, Stanford U., California, U.S.A.) — Post Archives at Midas Oracle
• Thomas C. Schelling – Thomas Schelling – (Economics, School of Public Affair, University of Maryland, Maryland, U.S.A.)
• Emile Servan-Schreiber – (NewsFutures, New York City, New York, U.S.A. & Paris, France, E.U.) — Post Archives at Midas Oracle
• Robert J. Shiller – Robert Shiller – Profile – (Economics, Yale University, Connecticut, U.S.A.)
• Bernd Skiera – (Electronic Commerce, Goethe University, Germany, E.U.)
• Vernon L. Smith – Vernon Smith – (Economics, Economic Science Institute, Chapman University, California, U.S.A.)
• Erik Snowberg – (Stanford University, California, U.S.A.) — Soon at CalTech
• Peter Norman Sorensen – (Finance, Department of Economics, University of Copenhagen, Denmark, E.U.)
• Martin Spann – (Marketing and Innovation, University of Passau, Germany, E.U.)
• Koleman Strumpf – Koleman S. Strumpf – (Economics, School of Business, University of Kansas, Kansas, U.S.A.) – Formerly: University of North Carolina, North Carolina, U.S.A.) — Post Archives at Midas Oracle
• Cass Sunstein – Cass R. Sunstein – (Law School, University of Chicago, Chicago, Illinois, U.S.A.)
• James Surowiecki – (The Wisdom Of Crowds) – (New York, U.S.A.)
• Paul C. Tetlock – Paul Tetlock – (Finance, Business School, University of Texas at Austin, Texas, U.S.A.) — Post Archives at Midas Oracle
• Philip Tetlock – Philip E. Tetlock – (Leadership, University of California at Berkeley, California, U.S.A.)
• Hal R. Varian – Hal Varian – (Chief Economist, Google, California, U.S.A.) — Formerly: (Haas School of Business, Department of Economics, University of California at Berkeley, California, U.S.A.)
• Dorina Tila – (Economics, George Mason University, Virginia, U.S.A.)
• Leighton Vaughan-Williams – (Economics and Finance, Business School, Nottingham Trent University, United Kingdom, E.U.)
• Michael Wellman – Michael P. Wellman – (Computer Science and Engineering, University of Michigan, Michigan, U.S.A.)
• Justin Wolfers – Justin J. Wolfers – (Business and Public Policy, Wharton Business School, University of Pennsylvania, Pennsylvania, U.S.A.) — Post Archives at Midas Oracle
• Eric Zitzewitz – Eric W. Zitzewitz – (Economics, Dartmouth College, Massachusetts, USA) – Formerly: (Stanford University, California, U.S.A.) — Post Archives at Midas Oracle

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The Journal of Prediction Markets

Editor:
Leighton Vaughan Williams

Associate Editors:
John Delaney – CEO InTrade
Bruno Deschamps – University of Bath
Olivier Gergaud РUniversit̩ de Reims Champagne-Ardennes
Robin Hanson – George Mason University
Charles Noussair – Emory University
Marco Ottaviani – Ex-London Business School
David Paton – Nottingham University Business School
Paul Rhode – University of Arizona
Emile Servan-Schreiber – CEO NewsFutures
Michael Smith – Canterbury University
Martin Spann – University of Passau
Koleman Strumpf – University of Kansas School of Business
Justin Wolfers – University of Pennsylvania
Erik Snowberg – Stanford Graduate School of Business
Eric Zitzewitz – Stanford Graduate School of Business

I’d answer “yes” to my questions stated in the title of this post. These guys should be judged on the quality of their intellectual output —me thinks. Period.

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Prediction Market Industry Association – (PMIA):

Prediction Market Industry Association – (PMIA)

Emile Servan-Schreiber T: +1 (443) 321-2700 E: ejss@newsfutures.com
Jed Christiansen T: +44 796 358 3663 E: jed.christiansen@mercury-rac.com
John Delaney T: +353 1 6200 300 E: john.delaney@intrade.com
Robin Hanson E: rhanson@gmu.edu
Justin Wolfers E: jwolfers@wharton.upenn.edu

I can understand that some, like Niall O’Connor, have reservations on this mixing of interests, though.

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But we should judge these scholars and professionals on what they deliver —not whom they talk to, or associate themselves with.

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Marco Ottaviani, professor of management and strategy, Kellogg School of Business, Northwestern University

I am pleased to note that Mat Fogarty (Founder and CEO, Xpree) and Alexander Costakis (Managing Director, HSX) have been added to the program.

Please get in touch with me (cigar@ku.edu) if you are interested in attending or have any questions.

Schedule

8:30 Registration, Coffee, Opening Remarks

9:00 Lessons from Corporate Applications of Prediction Markets

Henry Berg, Microsoft

Discussant: Robin Hanson (George Mason Department of Economics)

Christina Ann LaComb, GE (The Imagination Market; abstract is free, text is gated)

Discussant: Marco Ottaviani (Kellogg School of Management, Management and Strategy)

10:45 Coffee Break

11:00 Lessons from Corporate Applications of Prediction Markets (cont)

Dawn Keller, Best Buy (Best Buy’s TAGTRADE Market)

Discussant: Paul Rhode (Department of Economics. Eller College of Management, University of Arizona)

Bo Cowgill, Google (Putting Crowd Wisdom to Work)

Discussant: Eric Zitzewitz (Dartmouth Department of Economics)

12:45 Lunch

Keynote address: Jim Lavoie, Co-Founder and CEO, Rite-Solutions

1:45 Lessons from Prediction Market Organizers and Operators

John Delaney, Founder and CEO, Intrade

David Perry, Co-Founder and President, Consensus Point

Mat Fogarty, Founder and CEO, Xpree Inc

3:15 Break (refreshments)

3:30 The Legal Playing Field

Tom W. Bell, Chapman University School of Law

Discussant: Robert E. Litan (VP Research and Policy at the Kauffman Foundation, Senior Fellow at the Brookings Institution, Director of the AEI-Brookings Joint Center on Regulatory Studies)

4:15 General Discussion

Alexander Costakis (Managing Director, Hollywood Stock Exchange) will also be available to answer questions and may make a short presentation.

The preliminary schedule is listed below:

Schedule

8:30 Registration, Coffee, Opening Remarks

9:00 Lessons from Corporate Applications of Prediction Markets

Henry Berg, Microsoft

Discussant: Robin Hanson (George Mason Department of Economics)

Christina Ann LaComb, GE (The Imagination Market; abstract is free, text is gated)

Discussant: Marco Ottaviani (Kellogg School of Management, Management and Strategy)

10:45 Coffee Break

11:00 Lessons from Corporate Applications of Prediction Markets (cont)

Dawn Keller, Best Buy (Best Buy’s TAGTRADE Market)

Discussant: Paul Rhode (Department of Economics. Eller College of Management, University of Arizona)

Bo Cowgill, Google (Putting Crowd Wisdom to Work)

Discussant: Eric Zitzewitz (Dartmouth Department of Economics)

12:30 Lunch

Keynote address: Jim Lavoie, Co-Founder and CEO, Rite-Solutions

1:45 Lessons from Prediction Market Organizers and Operators

John Delaney, Founder and CEO, Intrade

David Perry, Co-Founder and President, Consensus Point

3:00 Break (refreshments)

3:15 The Legal Playing Field

Tom W. Bell, Chapman University School of Law

Discussant: Robert E. Litan (VP Research and Policy at the Kauffman Foundation, Senior Fellow at the Brookings Institution, Director of the AEI-Brookings Joint Center on Regulatory Studies)

4:00 General Discussion

6:30 Dinner

Location TBA

Marco Ottaviani

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Executive Summary

Prediction markets are markets for contracts that yield payments based on the outcome of an uncertain future event, such as a presidential election. Using these markets as forecasting tools could substantially improve decision making in the private and public sectors. We argue that U.S. regulators should lower barriers to the creation and design of prediction markets by creating a safe harbor for certain types of small stakes markets. We believe our proposed change has the potential to stimulate innovation in the design and use of prediction markets throughout the economy, and in the process to provide information that will benefit the private sector and government alike.

Introduction

Prediction markets are markets for contracts that yield payments based on the outcome of an uncertain future event, such as a presidential election, the release date for new software, or the action taken by the Federal Reserve on short-term interest rates. A key benefit is that the market price of these contracts can potentially provide more accurate forecasts of future events than other methods. Using these markets as forecasting tools could substantially improve decision making in the private and public sectors. They also can help manage risk more efficiently. It is precisely because prediction markets have great potential that we think the government should facilitate rather than hinder the introduction of these markets.

There are significant regulatory barriers to establishing prediction markets in the United States, in part because they are potentially subject to gambling laws. We argue that U.S. regulators should lower barriers to the creation and design of prediction markets by creating a safe harbor for certain types of small stakes markets. We believe our proposed change has the potential to stimulate innovation in the design and use of prediction markets throughout the economy, and in the process to provide information that will benefit the private sector and government alike.

[...]

Conclusion

We believe prediction markets can significantly improve decision making in both the private and public sectors. One of the clear benefits of allowing small stakes, non-profit markets to operate would be the greater use of prediction markets to inform both public and private decision making. A second benefit would be that access to better information could promote greater transparency and accountability in decision making. A third benefit might be that other countries and regions would promote prediction markets with more sensible regulation. Finally, we think there would be benefits from the development of new knowledge on how to design prediction markets.

We are aware that Congress did not intend the CFTC to regulate gambling and we believe that it is important to design this safe harbor in such a fashion that socially valuable prediction markets can get in, but gambling markets cannot.

Prediction markets have great potential for improving economic welfare and the decisions of private and public institutions alike. To help achieve that potential, the regulatory impediments to the use of prediction markets in the U.S. should be lowered. Here, we have suggested one approach for reducing those regulatory barriers.

AEI-Brookings Joint Center – The views in this paper represent those of the authors and do not necessarily represent the views of the institutions with which they are affiliated.

Kenneth J. Arrow – Stanford University

Robert Forsythe – University of South Florida

Michael Gorham – Illinois Institute of Technology

Robert Hahn – AEI-Brookings Joint Center

Robin Hanson – George Mason University

Daniel Kahneman – Princeton University

John O. Ledyard – California Institute of Technology

Saul Levmore – University of Chicago

Robert Litan – AEI-Brookings Joint Center

Paul Milgrom – Stanford University

Forrest D. Nelson – University of Iowa

George R. Neumann – University of Iowa

Charles R. Plott – California Institute of Technology

Thomas C. Schelling – University of Maryland

Robert J. Shiller – Yale University

Vernon L. Smith – George Mason University

Erik Snowberg – Stanford University

Cass R. Sunstein – University of Chicago

Paul C. Tetlock – University of Texas at Austin

Philip E. Tetlock – University of California at Berkeley

Hal R. Varian – University of California at Berkeley

Marco Ottaviani – London Business School

Justin Wolfers – University of Pennsylvania

Eric Zitzewitz – Stanford University

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