Galaxy Research warns that new CFTC guidance on "Mention Markets" cannot fully eliminate structural manipulation risks inherent in prediction contracts tied to individual speech. Unlike traditional event contracts, these markets settle based on autonomous personal actions, such as whether a specific individual mentions a keyword during a public appearance, creating unique vulnerabilities outside standard regulatory frameworks. The CFTC’s Division of Market Oversight advises exchanges to presume these markets are manipulation-prone and evaluate four factors before listing, including independent verification and public oversight. However, Galaxy Research notes the guidance is non-binding and lacks enforcement mechanisms against individuals who alter outcomes through speech without holding positions or coordinating with traders. Current market manipulation laws and First Amendment protections limit regulators' ability to police speech-driven outcomes absent economic interest, leaving a critical gap in oversight for this emerging asset class.