Case: 1:25-cv-15406 Document #: 43-1 Filed: 01/30/26 Page 15 of 17 PageID #:381
Ignoring history, context, and common sense, Coinbase presents an alternate reality in which a statutory scheme whose scope is limited to addressing the risk, discovery, and dissemination of commodity pricing information, see 7 U.S.C. § 5(a)–(b), exclusively governs nationwide sports betting, including that occurring on Indian lands. Coinbase therefore creates a world where Congress repealed the comprehensive regulatory scheme set forth in IGRA, similar state law structures, and the then-federal policy requiring states to prohibit sports betting, as codified in PASPA. And Coinbase incredibly argues all of this happened without even a whisper of legislative intent. 6 CONCLUSION For the foregoing reasons, the Tribal Amici respectfully request that the Court deny Coinbase’s motion for preliminary injunction.
6 As the Nevada District Court aptly stated, “[i]t is absurd to think that Congress intended for DCMs to turn into nationwide gambling venues on every topic under the sun to the exclusion of state regulation and with no comparable federal regulator without ever mentioning that was the goal when Congress added swaps to the CEA in 2010.” Hendrick , 2025 WL 3286282, at *9 (footnote omitted).
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