2:25-cv-575-APG-BNW MOTION HEARING - ROUGH DRAFT - DO NOT CITE!!!
18 Final 4, who qualifies for the Final 4, there are rules that Kalshi sets up, including you can't engage in this market if you're a coach or a participant or an alum or something like that. But what I don't know is, what's the enforcement mechanism? For instance, the Nevada Gaming Control Board has investigators, it goes out and looks for point shaving. They look at oddities in the sports betting, and that helps them identify when there's problems. And that's one of the great facilities and services that the Gaming Control Board provides to ensure legitimate betting. I see rules that Kalshi puts in place, but how does it monitor? How does it do anything to make sure those rules are followed and not broken? MR. HAVEMANN: So I can give Your Honor a high-level answer, and then I think I can be able to give a more specific answer, but the high-level answer is that the CEA requires, so one of the core principles requires any designated contract market to have the ability to make sure that its rules are being followed. So Kalshi has compliance officers and the like that look into this very thing. So if Your Honor needs a more specific answer, I'm happy to provide it, but the high-level answer is, as required by the CEA, one of, or I think actually more than one of, the core principles deal with precisely this issue, that is, making sure that designated contract markets have mechanisms in place
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UNITED STATES DISTRICT COURT Judy K. Moore, RMR, CRR
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