# Cleary Gottlieb

**Type:** Law firm  
**Focus:** Securities law, derivatives regulation  
**Relevance:** Premier securities law firm providing regulatory analysis of prediction markets

## Overview

Cleary Gottlieb is one of the premier securities law firms. Their March 2026 analysis of prediction market regulation identified the SEC security-based swap track as potentially relevant to company-specific event contracts, providing the first external practitioner analysis with statutory citation of the three-part test under 15 U.S.C. § 78c(a)(68).

## Timeline

- **2026-03-01** — Published comprehensive analysis of prediction market regulatory landscape including SEC jurisdiction over company-specific event contracts as security-based swaps

## Significance

Their identification of the SEC track without any blockchain/DAO analysis confirms the governance market gap extends to SEC-focused practitioners, not just CFTC-focused ones. The analysis is aimed at traditional corporate actors and contains no treatment of DAO governance markets or futarchy mechanisms.