Case: 25-1922 Document: 73 Page: 32 Date Filed: 08/14/2025
access requirements” such as “the creation of exclusive membership standards that focus on high net worth.” 75 Fed. Reg. 80,572, 80,579 & n.51 (Dec. 22, 2010). But a contract market can still “establish different categories of market participants” where it does not “discriminate within a particular category.” Id. at 80,579. So complying with New Jersey’s pro- hibition on this small slice of wagers does not make it “impossible” for Kalshi to provide impartial, nondiscriminatory access. At bottom, “Kalshi has not shown how obtaining a license in” New Jersey and “complying with” New Jersey “law would prevent it from com- plying with federal law.” Martin , 2025 WL 2194908, at *12. CONCLUSION This Court should reverse.
Respectfully submitted, MATTHEW J. PLATKIN ATTORNEY GENERAL OF NEW JERSEY
By: /s/ Stephen Ehrlich Stephen Ehrlich
Deputy Solicitor General R.J. Hughes Justice Complex 25 Market Street P.O. Box 112 Trenton, New Jersey 08625-0112 (609) 250-8412
Dated: August 14, 2025
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