2026 Membership Book FINAL

Case: 25-7516, 01/23/2026, DktEntry: 33.1, Page 84 of 110

people under 21 from gaming, NRS § 463.350(1)(a); Kalshi, by contrast, al-

lows anyone over 18 to bet on its platform, Kalshi Help Center, Signing Up

as an Individual (2025), perma.cc/2F8Y-REBP.

Nevada law also protects those suffering from problem gaming. It re-

quires licensees to offer deposit-limit tools and to prominently display the

State’s responsible-gaming resources. Nev. Gaming Regs. 5.225(18)(a)-(b).

“[N]either DCMs nor the CFTC is equipped to address those issues the same

way state gaming regulators and licensed entities are.” 1-ER-28.

Indeed, Kalshi gleefully describes its platform as “kind of addicting.”

Dustin Gouker, Kalshi Says It’s ‘Kind of Addicting’ In Instagram Post ,

Event Horizon (Oct. 21, 2025), perma.cc/5DWW-4LKE. Although Kalshi

says (Br. 67) that it offers consumer-protection tools, its efforts are entirely

voluntary and nowhere near as stringent as Nevada law. 1-ER-28. Indeed,

Kalshi’s counsel has disclaimed a desire for any limits: “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.” Danny Funt, America’s Betting Craze Has

Spread to Its News Networks , New Yorker (Dec. 12, 2025), perma.cc/77H2-

RH96.

Harm to the State’s economy and finances. Licensed gaming is

“vitally important to the economy of the State and the general welfare of the

inhabitants.” NRS § 463.0129(1)(a). In 2024, Nevada collected $2 billion in

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