Case 1:25-cv-14723 Document 10-1 Filed 08/19/25 Page 9 of 34 PageID: 81
“ KalshiEx ”), appeal filed , No. 25-1922 (3d Cir. May 8, 2025). Defendants are thus currently
prohibited from enforcing New Jersey gambling laws against Kalshi with respect to sports-
related event contract transactions on its designated exchange.
Robinhood received a nearly identical cease-and-desist letter from the Division on
March 27, 2025. Robinhood maintains that its conduct did not violate any state laws, but
nevertheless, Robinhood paused allowing New Jersey residents to enter new positions for sports-
related event contracts. Robinhood’s voluntary compliance with the Division’s unconstitutional
cease-and-desist letter has already caused Robinhood irreparable harm, including damage to its
reputation and goodwill and significant economic losses. In May, after this Court’s decision in
KalshiEx , Robinhood sought an agreement from the state of New Jersey to permit Robinhood at
least temporarily to offer its customers the same sports-related event contracts that are traded on
Kalshi’s exchange, which Kalshi is currently permitted to execute under this Court’s order
without fear of state law enforcement actions. Division employees indicated they could not
agree to refrain from enforcement action against Robinhood, even while the KalshiEx order is in
place. Despite repeated requests, the Division has failed even to respond to Robinhood’s request
for a meeting to discuss this issue with senior Division officials.
In light of this Court’s decision in KalshiEx , No. 25-cv-2152, 2025 WL 1218313, and the
Division’s refusal to reach an agreement with Robinhood to mitigate the substantial ongoing
economic and reputational harms Robinhood continues to suffer in the marketplace while Kalshi
is permitted to trade sports-related event contracts in New Jersey, Robinhood has reactivated its
New Jersey customers’ access to opening new positions in sports-related event contracts. As a
result, it now faces an immediate threat of civil penalties and criminal prosecution from the
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