Case 3:25-cv-02016-VDO Document 56-1 Filed 01/16/26 Page 3 of 29
U.S.C. §2702(1). IGRA has been incredibly successful on that front. 2 Since IGRA’s passage in 1988, tribes across the United States have lifted entire generations out of poverty through tribal gaming. Gaming revenue supports thousands of jobs in hundreds of communities and tribal government programs. It also provides critical funding to state and local governments through revenue-sharing agreements, tax revenue, and economic stimulus. In Connecticut, IGRA’s framework has allowed the Mashantucket Pequot Tribal Nation, Mohegan Tribe of Indians of Connecticut (collectively, “Connecticut Tribes”), and State of Connecticut to forge a historic and unique regulatory relationship over sports betting throughout the state and to protect their sovereign interests. It also promotes the health, safety, and welfare of each sovereign’s citizens through comprehensive gaming regulation and ensures that gaming revenue is used for the public’s benefit. In contrast, Kalshi, without any license or approval by the Connecticut Tribes or the State, brazenly entered onto state and tribal lands to conduct unregulated gaming with its so- called “legal sports betting” app. In doing so, Kalshi is siphoning away vital tribal and state governmental revenue directly into its owners’ private pockets. Tribes have primary jurisdiction over their lands and activities occurring thereon. Tribes, like states, also have a strong sovereign interest in determining what gaming activities may take place on their lands. Thus, tribal jurisdiction extends to gaming, which has long been recognized by the Supreme Court. See California v. Cabazon Band of Mission Indians , 480 U.S. 202, 218– 22 (1987); 25 U.S.C. § 2701(5). In 1988, Congress enacted IGRA “to provide a statutory basis
2 See, e.g. , National Indian Gaming Commission, FY 2023 Gross Gaming Revenue Report 4–5 (July 2024), available at https://www.nigc.gov/wp-content/uploads/2025/02/GGR23_Final.pdf.
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