Case 1:25-cv-12578-RGS Document 41-1 Filed 10/16/25 Page 23 of 24
authority. Robinhood not only violates IGRA, but strikes at the heart of tribal sovereignty and federal Indian policy by offering what is effectively unregulated nationwide online sports betting. Robinhood’s sports event contracts offered on Indian lands, therefore, diminish tribal bargaining power in compact negotiations and the value of the tribes’ bargained-for benefits. Finally, Robinhood is siphoning revenue from tribal governments in violation of federal Indian policy. IGRA requires all revenues from tribal gaming be used for governmental or charitable purposes. 25 U.S.C. § 2710(b)(2)(B). As Justice Sotomayor explained in Bay Mills : “[T]ribal gaming operations cannot be understood as mere profit-making ventures that are wholly separate from the Tribes’ core governmental functions.” 572 U.S. at 810 (Sotomayor, J., concurring). Many tribes have come to rely on gaming revenue because destructive former federal policies “left a devastating legacy” on tribes that are “largely unable to obtain substantial revenue by taxing tribal members … [because] there is very little income, property, or sales [that tribal governments] could tax.” Id. at 812–13 (quoting Matthew L.M. Fletcher, In Pursuit of Tribal Economic Development as a Substitute for Reservation Tax Revenue , 80 N.D. L. Rev. 759, 774 (2004)). If Robinhood continues to offer illegal nationwide online sports betting, the impact on tribal governments will be devastating. CONCLUSION For the foregoing reasons, the Tribal Amici respectfully request that the Court deny Robinhood’s motion for preliminary injunction and grant the Defendants’ motion to dismiss.
hard at state-regulated gambling , SBCAmericas, (July 11, 2025), available at ********sbcamericas.com/2025/07/11/kalshi-nclgs-sports-contract-debate/?amp. 23
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