2026 Membership Book FINAL

Case 1:25-cv-01283-ABA Document 26 Filed 05/09/25 Page 35 of 36

947 F.3d 207, 230 (4th Cir. 2020)). Here and as set forth in this Response ’ s supporting affidavits,

Kalshi’s unlicensed practice of sports wagering threatens to undercut Maryland’s licensed sp orts

book operators and endangers the revenues flowing to the State from those entities as wells as the

secondary benefits Maryland gains from entities reliant on the State thriving gaming industry.

Exhibit 3 at ¶¶ 13-17; Exhibit 4 at ¶¶ 10-21. In addition, Kalshi’s unlicensed busines s has not

demonstrated that it has the necessary integrity, financial stability, and responsible gaming

practices to ensure that Marylanders are not preyed upon. See Exhibit 6 at ¶¶ 4, 8-12, 13-14, 19;

Exhibit 4 at ¶¶ 17, 18.q1 In light of these factors and Kalshi’s unclean hands , the balance of

hardships weigh heavily in the Defendants favor.

CONCLUSION

Based on the foregoing, this Court should deny Kalshi’s Motion for a Preliminary

Injunction.

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