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Pre-IPO · Secondaries Series 2026

Cometum
Polymarket Bond
Invest before the IPO.

Structured secondary-market access to Polymarket — the world's largest decentralized prediction market platform. Exclusively for professional investors.

German SecurityISIN / WKNMin. €5,000From 15.06.2026

The bonds offered are an entrepreneurial investment with risks. In principle, a total loss of the invested capital cannot be ruled out.

€50m
Bond volume, with extension option
3 + 2 years
Term plus extension option
€1,000
Denomination per bond
IPO / Secondary
Clear exit strategies
Company Overview

The world's largest decentralized prediction market platform

Polymarket operates a blockchain-based order book where traders buy and sell outcome shares on real-world events via smart contracts — spanning sports, politics, crypto, geopolitics, and, since May 2026, private markets via Nasdaq Private Market integration. Traders post collateral in USDC stablecoin, and event probabilities emerge from real-time supply-and-demand pricing.

Following CFTC approval in late 2025 through its QCEX acquisition (a CFTC-licensed exchange and clearinghouse), Polymarket has legally re-entered the U.S. market and is transitioning from crypto-native platform into a regulated, institutional-grade market infrastructure business. The platform now hosts 1.3+ million traders and has processed USD 18.1 billion in cumulative trading volume, with global prediction market volume reaching USD 25.7 billion in March 2026 alone.

ICE, the parent of NYSE, has committed up to USD 2 billion, holds ~11% fully-diluted, and distributes Polymarket data globally through its financial terminal infrastructure. Exclusive multi-year sports partnerships (MLB ~USD 300M, TKO Group, NHL, MLS) and data distribution via X, Google Finance, and Yahoo Finance position the company as the emerging institutional layer bridging TradFi and DeFi — with an IPO pathway widely anticipated to follow Kraken's playbook.

CFTC-regulated U.S. Exchange (QCEX)ICE Anchor · up to $2B committedOfficial Prediction Market Partner of X
HeadquartersNew York, USA (US operations); international operations from Panama
Founded / Employees2020 / ~150 employees
IndustryFinancial Markets Infrastructure – Decentralized Prediction Markets
Core ProductsPolymarket Retail Platform, Polymarket Pro (institutional, launching year-end 2026), Polymarket Signals & Sentiment (via ICE), CFTC-regulated Exchange (via QCEX), Private Markets prediction contracts (via Nasdaq Private Market)
LeadershipShayne Coplan (Founder & CEO), Matthew Modabber (CMO)
Selected InvestorsICE (NYSE, ~$2B), Founders Fund, Peter Thiel, 1789 Capital, Vitalik Buterin, Nasdaq Private Market
Customers & Distribution PartnersMLB, TKO Group Holdings (UFC, Zuffa Boxing), NHL, MLS, X (Twitter), Google Finance, Yahoo Finance, Nasdaq Private Market
Valuation Development

Approximately 43× in 24 months —
and a reported $15B round in the making

Polymarket's last confirmed primary financing valued the company at ~USD 9 billion (Series D, October 2025, led by ICE). Secondary market indications reached USD 11.6 billion in January 2026, and Bloomberg reported in April 2026 that Polymarket is seeking a new USD 400 million round at ~USD 15 billion — not yet officially confirmed.

$20B$15B$10B$5B$0B$0.35B$1.0B$1.2B$1.0B$9.0B~$11.6BUndisclosed · 2024Series B · May 2024Undisclosed · Early 2025Series C · Jun 2025Series D (ICE) · Oct 2025Secondary · Jan 2026

Solid line = primary funding rounds (post-money). Open point = secondary-market indication (PM Insights, January 2026). The reported April 2026 round at ~USD 15 billion is based on market intelligence (Bloomberg) and not yet officially confirmed. Source: Cometum analysis based on public data and market research (CoinDesk, Bloomberg, Reuters, Financial Magnates, Sacra, PM Insights). All valuation figures are indicative. Secondary-market valuations represent observed transactions; actual transaction values may vary and do not necessarily reflect Cometum's entry price.

October 2025 · Series D (ICE)
USD 1B primary + USD 1B secondary at ~USD 9B post-money
Largest strategic investment by a major U.S. exchange operator in a crypto-native platform
January 2026
Secondary market implied valuation reaches ~USD 11.6B
Per PM Insights
March 27, 2026
ICE closes remaining USD 600m of prior commitment
Total ICE commitment ~USD 2 billion
April 2026 · Reported next round
USD 400m sought at ~USD 15B valuation
Reported by Bloomberg; not yet officially confirmed
Ownership Structure

A clear path from your investment
to Polymarket shares

Step 1
Investors
Step 2
Cometum's SPV
Step 3
External SPVs
Underlying
Polymarket Shares
1

Investors purchase the Cometum Bond — a German security with €1,000 denomination and €5,000 minimum subscription.

2

Cometum Direct Invest GmbH & Co. KG participates in one or more special purpose vehicles.

3

These special purpose vehicles are directly or indirectly holding the shares of Polymarket.

Assessment

Opportunities & Risks

Opportunities

  • Hyper-scaling market: global prediction market volume reached USD 25.7B in March 2026 (+10.6% MoM); Bernstein projects USD 240B for full-year 2026.
  • ICE strategic anchor: NYSE parent invested up to USD 2B, distributes Polymarket data globally to institutional clients — deepest TradFi validation.
  • Sports category explosion: MLB partnership worth up to USD 300M; TKO Group (UFC, Zuffa Boxing), NHL, MLS partnerships; NBA Finals USD 413M, 2026 World Cup USD 2.5B in 11 days.
  • Distribution ubiquity: X (official partner), Google Finance, Yahoo Finance, ICE terminal — collectively hundreds of millions of users.
  • CFTC compliance moat: QCEX acquisition provides legal U.S. operation; Palantir + TWG AI surveillance addresses regulator concerns.
  • POLY token airdrop: confirmed by CMO in Nov 2025 — potential retail engagement catalyst and additional monetization path.
  • Kraken-comparable IPO trajectory: founder Shayne Coplan rang the NYSE opening bell (Nov 2025) — strong signal for eventual public listing.
  • Kalshi-vs-Polymarket valuation gap: Kalshi at USD 22B vs. Polymarket at USD 9–15B — significant potential re-rating if market share stabilizes.

Risks

  • Kalshi market-share reversal: Kalshi captured ~65% of prediction market volume (Sep 2025) vs. Polymarket's 37% — dramatic reversal from Polymarket's 95% share in late 2024.
  • Regulatory scrutiny: ongoing U.S. congressional attention on prediction market manipulation; CFTC oversight tightening; global regulatory fragmentation.
  • Insider trading investigations: Israeli authorities arrested individuals in early 2026 for allegedly using classified info for Polymarket bets; The Guardian revealed organized manipulation attempts.
  • Historical legal overhang: FBI raid on founder's home in 2024 investigated possible 2022 CFTC settlement violation; QCEX acquisition mitigates but does not eliminate historic risk.
  • Political ties concentration: 1789 Capital (Trump Jr.-linked) as investor creates political-brand association that can cut both ways depending on the U.S. political cycle.
  • Category concentration: sports (~40%) and politics (32%) drive most volume — both event-driven and vulnerable to seasonal/cycle risk.
  • Kraken-comparable IPO timing risk: IPO anticipated to follow Kraken's playbook, but Kraken's 2026 IPO paused; prediction market IPO window may be delayed.
  • Valuation execution risk: ~43× valuation increase in 24 months; the April 2026 USD 15B round is reported but not confirmed.
  • Structural & FX risk: indirect exposure via structured bond; USD currency risk; total loss possible.
The Cometum Bond at a Glance

Clear terms. Clear exit strategies
via IPO or the secondary market.

Bond

Subordinated, unsecured bond providing structured participation in the performance of Polymarket — issued as a German security.

Cometum Fees
5.5%Entry Fee
5.0%Equity Option Fee
IssuerCometum Direct Invest GmbH & Co. KG
Type of InvestmentBond
Issuance VolumeUp to €50m with possible extension
Term3 years, plus extension option of up to 2 years
CouponVariable, payable at maturity
Bond StatusSubordinated, unsecured
Denomination€1,000
Minimum Subscription€5,000
Offer PeriodFrom 15.06.2026
Management Team

Capital markets expertise,
built for private markets

CEO & Founder

Sascha Miller

Lawyer specialized in banking and capital markets law. Previously Ashurst LLP and CACEIS Bank.

sascha.miller@cometum.com
CIO & Founder

Uwe Passmann

Specialist in Wealth Management & B2B Sales. Previously Scalable Capital and Reimann Investors.

uwe.passmann@cometum.com

Request access to the Polymarket Bond

Available exclusively to professional clients as defined by MiFID II. Contact our team to receive the offering documents, terms and conditions, and the full risk notice.

Only the information provided in the issuer's offering documents is decisive for the assessment of the bond.
Contact the Team

Risk Notice

By purchasing a bond, the purchaser takes on a significant risk which may result in the complete loss of the capital invested. The information provided here is merely non-binding promotional material and, in its nature and form, expressly does not constitute financial or any other form of investment advice. The information provided does not in any way replace investment advice tailored to the investor's individual circumstances and needs. The issuer expressly draws attention to the following points: The assessment of the bond is therefore based exclusively on the information contained in the issuer's (Cometum Direct Invest GmbH & Co. KG) offering documents, i.e. the terms and conditions of the bond and the risk disclosure. None of the information constitutes either an invitation to make an offer to purchase, or an offer to subscribe for or purchase the issuer's bond. Cometum is not a bank, but merely an issuer and product provider for exclusive private markets products. This investment does not involve the direct purchase of Polymarket shares by the investor, but rather a structured investment that enables participation in the performance of Polymarket. The information regarding the current valuation of Polymarket is provided for information purposes only. The valuation at which a structured investment in Polymarket is made may differ from the current market valuation. It does not reflect an indicative entry price of Cometum. The company operates in a highly competitive market environment shaped by regulatory developments and geopolitical uncertainties. The strategic focus is on technology-oriented clients who demand innovative solutions and a high degree of adaptability. Cometum participates directly or indirectly, via one or more holdings in special purpose vehicles, which in turn hold a direct interest in Polymarket. The Polymarket bond therefore constitutes an entrepreneurial capital investment involving risks. In principle, a total loss of the capital invested cannot be excluded. The share of Polymarket is listed in the foreign currency US Dollar ("USD"). It is therefore subject not only to standard market price fluctuations, but also to exchange rate risk. Changes in the exchange rate between the Euro and the USD can affect the performance and the Euro-denominated return of the investment both positively and negatively. An appreciation of the Euro against the USD may lead to losses, even if the price of the Polymarket share has risen in its home currency USD. Additional fees may apply at underlying participation levels (management fees, performance fees, exit fees, fees in connection with an IPO). The exact number of Polymarket shares outstanding is not necessarily publicly known or fixed at the time of the investment. Polymarket may issue additional shares — for example in connection with its IPO, the financing of an acquisition, further financing rounds, or employee participation programmes. Such issuances dilute existing holders: the total number of shares increases, and the proportion of the company attributable to each existing share decreases accordingly. As a result, the valuation at which the structured investment was entered into may, in retrospect, prove higher relative to the effective per-share basis and may change to the investor's disadvantage. In particular, the total valuation of the company may increase while the value attributable to an individual share — and thus to the investor's investment — does not increase to the same extent, or may even decline. The headline valuation figures stated in this material are therefore not a reliable indicator of the performance of the investor's investment, which depends on the per-share value at the relevant point in time. This presentation constitutes merely a non-binding invitation to make an offer (invitatio ad offerendum) and is purely informational in nature.