Case 3:25-cv-02016-VDO Document 56-1 Filed 01/16/26 Page 8 of 29
ia/oig/pdf/508%20Compliant% 202021.09.10%20Mashantucket%20Pequot%20Tribe%20Secretarial%20Procedures_0.pdf; Agreement Between the Mohegan Tribe of Indians of Connecticut and the State of Connecticut (Sep. 10, 2021) (hereinafter “Mohegan Agreement”), https://www.bia.gov/ sites/default/files/dup/assets/as-ia/oig/pdf/508%20Compliant%202021.09.15%20Mohegan %20Compact%20Amendment_0.pdf; see also Approval of Tribal-State Class III Gaming Compact in the State of Connecticut, 86 Fed. Reg. 51369 (Sep. 15, 2021). Under the terms of these agreements, and pursuant to state law, the two Connecticut Tribes and the Connecticut Lottery are each entitled to one of the three sports-betting licenses available in the State and thus have the exclusive authority to offer online sports betting in Connecticut. See, e.g., Conn. Gen. Stat. §§ 12-851, 12-852, 12-853, 12-863(a)(1). The agreements were approved by the Department of the Interior, 86 Fed. Reg. 51369, and ensure annual payments to the State in exchange for the Connecticut Tribes’ ability to operate online sports wagering under the regime carefully crafted by the Connecticut Tribes and State. See generally Mashantucket Pequot Agreement; Mohegan Agreement. This regulatory framework is comprehensive: federal, tribal, and state regulations apply to every aspect of online sports wagering, and the Tribal-State agreements ensure that there are no jurisdictional gaps. 3
3 The Connecticut Tribes offer online sports betting both on and off their Indian lands. All sports-betting activity that occurs outside their Indian lands uses a server located off-reservation, is governed by state law, and is regulated by the Connecticut Department of Consumer Protection. See Conn. Gen. Stat. §§ 12-851, 12-852, 12-862. All sports-betting activity that occurs on their Indian lands uses a server located on-reservation, and is governed strictly by the IGRA compacts or secretarial procedures. Unlike Kalshi, the State of Connecticut put great care into crafting a regulatory relationship with the Connecticut Tribes that does not infringe upon IGRA or the Connecticut Tribes’ rights to offer commercial gaming on their Indian lands.
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