Case 3:25-cv-06162-JSC Document 35 Filed 09/04/25 Page 2 of 34
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contracts that facially involve, relate to, or reference the sports of baseball, tennis, pickleball,
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soccer, basketball, football, golf, chess, esports, hockey, motorsports, the Ultimate Fighting
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Championship (“UFC”), and any other sports events. The Tribes further request that the Court
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enjoin Kalshi from offering on the Tribes’ Indian lands contracts that take the form of a binary
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“yes/no” event contract that pose the following questions:
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1. “Will <team> win <title>?”
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2. “Will <team> win <event>?”
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and any subsequent permutation, alteration, or variation of such contracts that facially involve,
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relate to, or reference sports, constitute or mimic sports betting, or any other potential class III
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gaming activity.
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The Tribes further respectfully request that Court enjoin Kalshi from marketing its sports
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contracts as “legal in all 50 states” or any variation of that phrase or similar representation
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regarding the nationwide legality of these gaming contracts.
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This motion is based on this notice, the Complaint for Declaratory and Injunctive Relief
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(ECF No. 1); the accompanying Memorandum of Points and Authorities; the supporting
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declarations filed herewith; the request for judicial notice filed herewith; all pleadings already on
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file with the Court in this case; and any matters properly before the Court.
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DATED: September 4, 2025
Respectfully Submitted,
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RAPPORT AND MARSTON
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/s/ Lester J. Marston L ESTER J. M ARSTON , Attorney for Plaintiffs
By:
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NOTICE OF MOTION AND MEMORANDUM OF POINTS AND AUTHORITIES [ Case No.: 25-cv-06162-JSC] ii
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