Case 1:25-cv-14723 Document 10 Filed 08/19/25 Page 2 of 3 PageID: 71
This motion is made on the grounds that: (1) Robinhood is likely to succeed on
the merits of its claim that Defendants’ threatened enforcement of New Jersey gambling laws is
preempted by the Commodity Exchange Act and the Commodity Futures Trading Commission’s
regulations pursuant to the Supremacy Clause of the U.S. Constitution; (2) absent a temporary
restraining order and preliminary injunction, Robinhood is likely to suffer irreparable harm; (3)
the balance of harms tips sharply in Robinhood’s favor; and (4) the public interest supports an
injunction.
This motion is based upon the Complaint in this action, the Memorandum of
Points and Authorities filed herewith, 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.
Plaintiff hereby requests, pursuant to Federal Rule of Civil Procedure 65, that the
Court issue a temporary restraining order and preliminary injunction.
2
Made with FlippingBook - Online catalogs