Joint filing targets the SEC
Hyperliquid Policy Center and tradeXYZ have filed a joint comment letter with the U.S. Securities and Exchange Commission, proposing that pre-IPO perpetual contracts, or IPOP, be included in the agency’s IPO modernization framework.
The proposal would let investors trade exposure to a company’s share price before the company lists, while creating a public and continuous market-based price signal.
What IPOP is meant to be
According to the filing, IPOP does not represent company equity. It does not give holders voting rights or any other shareholder rights. It is designed only to provide price exposure, and its pre-IPO function would end once the relevant company completes its listing.
tradeXYZ says it has already run five markets
tradeXYZ said it has completed five IPOP markets on Hyperliquid, including Cerebras, SpaceX, SK Hynix and CXMT.
The two groups said the pre-listing prices in some of those markets were close to the opening prices after the companies’ stock listings, arguing that the setup could give issuers and underwriters another public price-discovery signal.
Regulatory classification remains the key ask
They also urged the SEC and the Commodity Futures Trading Commission to clarify the regulatory classification of stock-like perpetual contracts, and to establish rules covering disclosure, listing eligibility, market-manipulation prevention, leverage and position limits.
Their stated end goal is to allow U.S. investors, including retail traders, to participate in the pre-IPO perpetual market.

