Kalshi is offering: contracts that stake or risk something of value upon the outcome of a sporting event based on the understanding that the person will receive something of value based on that outcome. In fact, Kalshi has repeatedly referred to its own sports event contracts as “bets” or “sports betting.” 3 Kalshi’s sports event contracts therefore clearly constitute sports betting and are thus Class III gaming under IGRA. Users as young as 18 years-old can bet on sports through Kalshi’s platform on the lands of hundreds of tribes across the United States. Kalshi has not obtained a license to offer these bets pursuant to any tribal ordinance or resolution; nor has Kalshi been authorized to conduct its sports betting pursuant to any tribal-state compact. Across the board, Kalshi does not restrict its sports event contracts and therefore offers such on Indian lands without complying with IGRA. Therefore, each bet Kalshi offers and facilitates on Indian lands is a violation of IGRA. These violations are highly impactful—they undermine tribal sovereignty and encroach on tribal gaming revenue and critical government funding. B. The CEA does not preempt IGRA
3 See Dustin Gouker, Ten Times Kalshi Said People Could Bet On Things , Event Horizon (Apr. 3, 2025), available at https://nexteventhorizon.substack.com/p/ten- times-kalshi-said-people-could.
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