Case 3:25-cv-02016-VDO Document 56-1 Filed 01/16/26 Page 27 of 29
all other tribes, states, and businesses offering sports betting across the country. The effects of Kalshi’s self-certification go even further; in Kalshi’s view, it can block tribes and states from regulating that which has long been within their sovereign authority to regulate simply by listing sports-betting contracts on its exchange. As the Supreme Court has stated, “[t]his is legislative delegation in its most obnoxious form; for it is not even delegation to an official or an official body, presumptively disinterested, but to private persons whose interests may be and often are adverse to the interests of others in the same business.” Carter Coal , 298 U.S. at 311. CONCLUSION For the foregoing reasons, the Tribal Amici respectfully request that the Court deny Kalshi’s motion for preliminary injunction. Dated: January 16, 2026 Respectfully submitted, By: /s/ Thomas J. Murphy Thomas J. Murphy (ct07959)
Bryan Newland ( pro hac vice pending) Powers, Pyles, Sutter & Verville PC 1250 Connecticut Ave N, 8th Floor Washington, DC 20036 (202) 349-4265 Bryan.Newland@powerslaw.com Counsel for Mohegan Tribe of Indians of Connecticut, Rincon Band of Luiseño Indians, and Santa Ynez Band of Chumash Mission Indians Scott Crowell ( pro hac vice pending) Crowell Law Office
Cowdery, Murphy & Healy, LLC 280 Trumbull Street, 22nd Floor Hartford, CT 06103 (860) 278-5555
tmurphy@cmandh.com Counsel for Tribal Amici
Joseph H. Webster ( pro hac vice pending) Elizabeth A. Bower ( pro hac vice pending) Jens W. Camp ( pro hac vice pending) Hobbs, Straus, Dean & Walker LLP 1899 L Street NW, Suite 1200 Washington, DC 20036 (202) 822-8282
Tribal Advocacy Group PLLC 1487 W State Rte 89A, Suite 8 Sedona, AZ 86336 (425) 802-5369 scottcrowell@clotag.net
jwebster@hobbsstraus.com ebower@hobbsstraus.com jcamp@hobbsstraus.com Counsel for Tribal Amici
Counsel for Rincon Band of Luiseño Indians, Santa Ynez Band of Chumash Mission Indians, and Spokane Tribe of the Spokane Reservation
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