2026 Membership Book FINAL

Case: 25-1922 Document: 83 Page: 7

Date Filed: 09/24/2025

Page 6

1 it inserted the word swap into the Commodities Exchange Act in

2 2010 as part of the Dodd-Frank reforms. The reason this is

3 such a massive sea change is because swaps have to be traded on

4 CFTC regulated exchanges on a designated contract market, and

5 it's, in fact, a federal crime to trade them outside of those

6 scenarios, and so what we have here is a definition by Kalshi

7 that would essentially make all casinos and sportsbooks

8 currently federal felons. We think that's certainly not what

9 Congress was trying to do. We don't think that's what the

10 Supreme Court in Murphy was envisioning when they struck down

11 PASPA and said, we're leaving this for the states to regulate.

12 They didn't mean we're leaving it to the CFTC, and that was

13 only seven years ago. They expected this to be something that

14 the states regulate, and I think what the -- part of the issue

15 here --

16

JUDGE CHAGARES: Let's jump into this now.

17

MR. EHRLICH: Uh-huh.

18

JUDGE CHAGARES: We're -- because we don't have all

19 that much time. So I -- it seems that that the definition of

20 swaps is actually quite broad, and I understand you point out

21 some things that seem undesirable to your side, but I mean, for

22 instance, I noticed in your brief, you -- I don't know if

23 there's a suggestion on a limitation, but you suggest something

24 should be inherently financial, economic, whatever, but that's

25 not in the statute. Are we obliged to, to apply what the

Veritext Legal Solutions 215-241-1000 ~ 610-434-8588 ~ 302-571-0510 ~ 202-803-8830

Made with FlippingBook - Online catalogs