Case 2:25-cv-01541-JCM-DJA Document 7 Filed 08/19/25 Page 8 of 31
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Plaintiff Robinhood Derivatives, LLC (“Robinhood”) moves this Court pursuant to Federal Rule of Civil Procedure 65 for a temporary restraining order and preliminary injunction against Defendants Mike Dreitzer, in his official capacity as Chairman of the Nevada Gaming Control Board; George Assad, in his official capacity as a Member of the Nevada Gaming Control Board; Chandeni K. Sendall, in her official capacity as a Member of the Nevada Gaming Control Board; Nevada Gaming Control Board, a subdivision of the State of Nevada; Jennifer Togliatti, in her official capacity as Chair of the Nevada Gaming Commission; Rosa Solis- Rainey, in her official capacity as a Member of the Nevada Gaming Commission; Brian Krolicki, in his official capacity as a Member of the Nevada Gaming Commission; George Markantonis, in his official capacity as a Member of the Nevada Gaming Commission; Nevada Gaming Commission, a subdivision of the State of Nevada; and Aaron D. Ford, in his official capacity as Attorney General of Nevada. This motion is based upon the Complaint in this action, the Memorandum of Points and Authorities contained in this document, the Declaration of James B. Mackenzie filed herewith along with its accompanying exhibits, the Declaration of Kevin J. Orsini filed herewith along with its accompanying exhibits, all matters with respect to which this Court may take judicial notice and such oral and documentary evidence as may be presented to the Court. PRELIMINARY STATEMENT The Robinhood organization consists of various financial-services companies that are democratizing finance by removing barriers to access to financial markets. Robinhood Derivatives, LLC, one of the family of companies within the Robinhood organization, is a Commodity Futures Trading Commission (“CFTC”)-registered futures commission merchant (“FCM”) that offers its approved users the opportunity to trade, among other things, sports- related event contracts through the Robinhood platform. While Robinhood, as a registered FCM, facilitates the placement and liquidation of event contracts for its users, the contracts themselves trade on KalshiEx LLC’s (“Kalshi”) exchange, which is registered with the CFTC as a designated contract market (“DCM”). Thus, while Robinhood’s approved users access event
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