2026 Membership Book FINAL

Case 2:25-cv-01541-APG-DJA Document 32 Filed 09/30/25 Page 19 of 21

protect consumers, ensure fairness, or mitigate negative gaming impacts. 17 In fact, Robinhood’s sports event contracts are wholly unregulated by any gaming authority. Robinhood not only

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violates IGRA, but strikes at the heart of tribal sovereignty and federal Indian policy by offering

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what is effectively unregulated nationwide online sports betting. Robinhood’s sports event

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contracts offered on Indian lands, therefore, diminish tribal bargaining power in compact

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negotiations and the value of the tribes’ bargained-for benefits.

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Finally, Robinhood is siphoning revenue from tribal governments in violation of federal

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Indian policy. IGRA requires all revenues from tribal gaming be used for governmental or

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charitable purposes. 25 U.S.C. § 2710(b)(2)(B). As Justice Sotomayor explained in Bay Mills :

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“[T]ribal gaming operations cannot be understood as mere profit-making ventures that are wholly

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separate from the Tribes’ core governmental functions.” 572 U.S. at 810 (Sotomayor, J.,

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concurring). Many tribes have come to rely on gaming revenue because destructive former federal

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policies “left a devastating legacy” on tribes that are “largely unable to obtain substantial revenue

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by taxing tribal members … [because] there is very little income, property, or sales [that tribal

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governments] could tax.” Id. at 812–13 (quoting Matthew L.M. Fletcher, In Pursuit of Tribal

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Economic Development as a Substitute for Reservation Tax Revenue , 80 N.D. L. Rev. 759, 774

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(2004)). If Robinhood continues to offer illegal nationwide online sports betting, the impact on

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tribal governments will be devastating.

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17 This lack of responsible gaming measures and consumer protections, which are required by legal gaming operations, is dangerous and contrary to the public interest. However, in a recent panel at the National Council of Legislators from Gaming States, Josh Sterling (a former CFTC employee and the lawyer representing Kalshi in concurrent litigation) dismissed such responsible gaming concerns, stating: “People are adults, and they’re allowed to spend their money however they want it, and if they lose their shirt, that’s on them.” Jessica Welman, Kalshi’s lawyer goes hard at state-regulated gambling , SBCAmericas, (July 11, 2025), available at https://sbcamericas.com/2025/07/11/kalshi-nclgs-sports-contract-debate/?amp.

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