Case 4:25-cv-14092-SDK-KGA ECF No. 29-1, PageID.502 Filed 01/26/26 Page 13 of 32
Exchange Act (“CEA”) would amount to a sub silentio reversal of congressional policy and Supreme Court precedent; nullify existing tribal-state gaming compacts and regulatory frameworks; allow Coinbase and its partner Kalshi—not states or tribes—to regulate its sports-betting activity on Indian lands; permit Coinbase to siphon gaming revenues from tribal and state governments; and diminish tribal self-determination. In Michigan in particular, Coinbase’s theory would completely undermine the Tribal-State Gaming Compacts (“Compacts”) between the Michigan Tribes and State that carefully and thoroughly balance both tribal and state interests over the regulation of gaming throughout Michigan. Accordingly, this Court should deny Coinbase’s motion for preliminary injunction. ARGUMENT I. Congress Did Not Repeal IGRA or the Tribal-State Gaming Compacts Between the State of Michigan and Michigan Tribes. A. IGRA’s Structure In IGRA, Congress explicitly stated that no class III gaming can occur on “Indian lands” unless it is authorized by the tribal government and is in a state that permits such gaming. 25 U.S.C. § 2710(d)(1). Class III gaming—including sports betting—is authorized on Indian lands only where tribes and states have entered into a compact or procedures prescribed by the Secretary of the Interior to regulate that gaming. Id. § 2710(d)(1), (d)(7)(B)(vii); see 25 C.F.R. § 502.4(c). This rule
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