"Operating commercial services" means that members of the general public can download the Waymo app (or access Waymo through a partner app), request a ride with pickup and dropoff locations within Denver, CO, and receive autonomous vehicle service for a fee. The service must be available to the general public without requiring special invitation codes, waitlist approval, or participation in testing programs, though geographic coverage within Denver, CO may be limited to certain areas. Services operating exclusively with safety drivers present do not satisfy the Payout Criterion; the service must offer fully autonomous rides (without a human safety driver) at least some of the time. Examples that WOULD resolve to Yes: Waymo launches public commercial service in any part of Denver, CO Waymo expands from adjacent areas into Denver, CO limits Waymo operates 24/7 service or limited hours service within Denver, CO Waymo offers service through the Uber app to all users in Denver, CO Service is geofenced to only certain neighborhoods but is public Examples that would resolve to No: Waymo only operates employee shuttles or closed testing in Denver, CO Waymo only has an office or maintenance facility in Denver, CO All Waymo vehicles in Denver, CO have safety drivers Waymo is testing but not offering paid public rides Service requires being on a waitlist or having a special code Waymo announces plans to launch but hasn't started service by Jan 1, 2027