Case 4:25-cv-14092-SDK-KGA ECF No. 29-1, PageID.501 Filed 01/26/26 Page 12 of 32
In Michigan, IGRA’s framework has allowed the twelve federally recognized Indian tribes within Michigan 3 (collectively the “Michigan Tribes”) and State of Michigan to forge a historic and unique regulatory relationship over sports betting throughout the state and to protect their sovereign interests. In 2021, the Michigan Tribes became the first tribes in the United States to operate statewide online sports wagering. This partnership also promotes the health, safety, and welfare of each sovereign’s citizens through comprehensive gaming regulation and ensures that gaming revenue is used for the public’s benefit. In contrast, Coinbase, without any license or approval from the Michigan Tribes or the State, brazenly entered onto state and tribal lands to conduct unregulated gaming. In doing so, Coinbase is siphoning away vital tribal and state governmental revenue directly into its owners’ private pockets. Coinbase now asks this Court to subvert the longstanding and comprehensive regulatory regime of IGRA. Its reading of the Commodity
3 These Tribes include: Bay Mills Indian Community, Grand Traverse Band of Ottawa and Chippewa Indians, Hannahville Indian Community, Keweenaw Bay Indian Community, Lac Vieux Desert Band of Lake Superior Chippewa Indians, Little River Band of Ottawa Indians, Little Traverse Bay Bands of Odawa Indians, Match-E-Be-Nash-She-Wish Band of Pottawatomi Indians (Gun Lake Tribe), Nottawaseppi Huron Band of Potawatomi, Pokagon Band of Potawatomi Indians, Saginaw Chippewa Indian Tribe of Michigan, and Sault Ste. Marie Tribe of Chippewa Indians.
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