Case 3:25-cv-02121-VDO Document 58-1 Filed 01/16/26 Page 4 of 29
for the regulation of gaming by an Indian tribe…to ensure that the Indian tribe is the primary beneficiary of the gaming operation, and to ensure that gaming is conducted fairly and honestly by both the operator and players ….” 25 U.S.C. § 2702(2). Coinbase asks this Court to subvert this longstanding and comprehensive regulatory regime. The consequences of Coinbase’s arguments are difficult to overstate. Its reading of the Commodity Exchange Act (“CEA”) would amount to a sub silentio reversal of congressional policy and Supreme Court precedent; nullify existing tribal-state gaming compacts and regulatory frameworks; allow Coinbase and its partner Kalshi—not states or tribes—to regulate its sports-betting activity on Indian lands; permit Coinbase to siphon gaming revenues from tribal and state governments; and diminish tribal self-determination. In Connecticut in particular, Coinbase’s theory would completely undermine the seminal agreements between the Connecticut Tribes and State that carefully and thoroughly balance both tribal and state interests over the regulation of gaming—including the State’s and Connecticut Tribes’ exclusive right to offer and regulate sports betting. Accordingly, this Court should deny Coinbase’s motion for preliminary injunction. ARGUMENT I. Congress Did Not Repeal IGRA or the Tribal-State Gaming Compacts Between the State of Connecticut and Connecticut Tribes. A. IGRA’s Structure In IGRA, Congress explicitly stated that no class III gaming can occur on “Indian lands” unless it is authorized by the tribal government and is in a state that permits such gaming. 25 U.S.C. § 2710(a)–(b), (d). Class III gaming—including sports wagering—is authorized on Indian lands only where tribes and states have entered into a compact or procedures prescribed by the Secretary of the Interior to regulate that gaming. 25 U.S.C. §§ 2710(d)(1),
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