2026 Membership Book FINAL

Case: 25-1922 Document: 83 Page: 15 Date Filed: 09/24/2025

Page 14

1 Again, they shouldn't be trading these on DCMS at all, and so

2 the fact that they're allowed to do it, subject to some

3 restrictions under our law, doesn't create a conflict here, and

4 so for that reason, we would say there's certainly no conflict.

5 I think the parties agree that conflict preemption could apply.

6 I think a lot of the arguments revolve around field preemption.

7 It's just that in this case, in the sports gambling case where

8 Congress has repeatedly --

9

JUDGE CHAGARES: What is a field anyway, if it's field

10 preemption?

11

MR. EHRLICH: Sorry, Your Honor?

12

JUDGE CHAGARES: What is the field?

13

MR. EHRLICH: Well, I think you'd have to ask Kalshi

14 that. I mean, we don't think there is a field. I think they

15 would say all trading on designated contracts markets, which

16 is -- I think we would say clearly not true. I think the

17 Seventh Circuit in the American Agriculture case --

18

JUDGE CHAGARES: Right, right.

19

MR. ERLICH: -- that both parties cite, says not field

20 preemption, so I don't know the answer to that, but that's why

21 we say there's no field preemption.

22

JUDGE CHAGARES: All right. Do you have anything,

23 Judge Porter?

24

JUDGE PORTER: Well, just given the posture of the

25 case on the preliminary injunction on the first prong, you

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