Case: 1:25-cv-15406 Document #: 43-1 Filed: 01/30/26 Page 2 of 17 PageID #:368
(collectively, “Tribal Amici”) respectfully submit this brief in support of Defendants’ response to Coinbase Financial Markets, Inc.’s (“Coinbase”) motion for preliminary injunction. STATEMENT OF INTEREST As described more fully in their Motion for Leave to File Amicus Brief, IGA, NCAI, AIGA, CNIGA, MIGA, OIGA, WIGA, USET SPF, NTGCR, NAFOA, TASIN, SMGHA, and the Amici Tribes all have a shared, strong interest in this case because of its potential to have a significant impact on tribal sovereign rights regarding gaming on Indian lands. Tribal gaming revenue provides vital funding for essential government services, tribal programs, and economic development. INTRODUCTION AND SUMMARY OF ARGUMENT Coinbase comes before this Court and asks it to wholly abandon the national policy of state and tribal sports-betting regulation and to turn decades of federal law on its head. The Court should not be persuaded to do so. America’s history is replete with prospectors taking resources from Indian lands without permission from Tribes. But Congress put a stop to that practice long ago. Yet Coinbase would have this court believe that, without so much as a whisper of legislative intent, Congress gave it permission to enter Indian lands and siphon gaming revenues away from tribes over such tribes’ objections. Congress did no such thing. When Congress adopted the Indian Gaming Regulatory Act (“IGRA”), it sought to “promot[e] tribal economic development, self-sufficiency, and strong tribal governments.” 25
Mission Indians; Pechanga Band of Indians; Pueblo of Acoma; Pueblo of Sandia; Rincon Band of Luiseño Mission Indians; San Pasqual Band of Diegueno Mission Indians of California; Santa Ynez Band of Chumash Mission Indians; Seminole Tribe of Florida; Spokane Tribe of the Spokane Reservation; Sycuan Band of the Kumeyaay Nation; Table Mountain Rancheria; Tunica-Biloxi Indian Tribe; and Yuhaaviatam of San Manuel Nation.
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