Case 1:25-cv-12578-RGS Document 41-1 Filed 10/16/25 Page 2 of 24
submit this brief in support of the Defendants’ combined motion to dismiss and response to Robinhood Derivatives, LLC’s (“Robinhood”) motion for preliminary injunction. STATEMENT OF INTEREST As described more fully in their Motion for Leave to File Amicus Brief, the Tribal Amici all have a shared, strong interest in this case because of its potential to have a significant impact on their or their member tribes’ sovereign rights regarding gaming on Indian lands, as well as Indian gaming and tribal governmental revenue as a whole. Such revenue is vital and provides funding for essential government services, tribal programs, and economic development needed to reach the goals of self-governance and self-sufficiency. ARGUMENT Indian tribes are sovereign nations with primary jurisdiction over their lands and the activities occurring on their lands. In accordance with this principle, both the United States Supreme Court and Congress have recognized tribes’ inherent and exclusive sovereign right to conduct and regulate gaming on their Indian lands. California v. Cabazon Band of Mission Indians , 480 U.S. 202 (1987); 25 U.S.C. § 2701(5). The Indian Gaming Regulatory Act (“IGRA”) was enacted to provide a comprehensive federal regulatory framework for tribal gaming, including a mechanism for tribes and states to negotiate compacts governing Class III gaming, such as sports betting, subject to federal approval. See 25 U.S.C. §§ 2702, 2703(8), 2710(d)(3). IGRA is intended to balance state, federal, and tribal interests. Chicken Ranch Rancheria of Me-Wuk Indians v. California , 42 F.4th 1024, 1032 (9th Cir. 2022). Some states have negotiated compacts wherein tribes are the exclusive operators of certain types of gaming within the state. E.g. , Artichoke Joe’s California Grand Casino v. Norton , 353 F.3d 712, 718 (9th Cir.
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