Case 3:25-cv-02121-VDO Document 58-1 Filed 01/16/26 Page 9 of 29
The Tribal-State agreements also provide both the Connecticut Tribes and State with vital funding for government services. For the State, all tax revenue and tribal revenue-sharing payments generated by sports betting in Connecticut go into the “Connecticut General Fund,” which is then “redistributed to various state programs, including education, infrastructure investments, policing and emergency services.” American Gaming Association, State of the States: Connecticut at 34–35 (May 2025), https://www.americangaming.org/wp- content/uploads/2025/05/AGA-State-of-the-States-2025.pdf. Similarly, consistent with IGRA, the Connecticut Tribes use their gaming revenue for the public benefit, such as “help[ing] fund operations of local government agencies” and “tribal government operations [and] programs.” See 25 U.S.C. § 2710(b)(2)(B), (d)(2). Additionally, through these agreements and state law, the Connecticut Tribes and State have set up a comprehensive system of regulation over sports betting to protect consumers. For example, under this system, the three sovereigns prohibit anyone under the age of 21 from placing sports bets and enforce stringent problem-gambler measures to protect the public more broadly. See , e.g. , Conn. Gen. Stat. § 12-863. Under the State’s regulations, individuals are prohibited from placing a wager if they pose a threat to the integrity of gaming due to cheating. Regs. Conn. State Agencies § 12-865-1(67)(E). In the case of fantasy contests, operators must prevent the sharing of inside information that may affect the outcome of a fantasy contest. Regs. Conn. State Agencies § 12-865-22(a)(1). Lastly, both the tribal-state agreements and State law expressly define “sports betting” to include exactly the type of betting that Coinbase offers. See Mashantucket Pequot Agreement, § 1(nn) (defining “sports wagering” as “risking or accepting any money … or other thing of value for gain contingent in whole or in part, (A) by any system or method of wagering, … and
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