Lincoln and Feinstein, the amendment’s principal drafter explained Congress intended the Special Rule “to prevent derivatives contracts that are contrary to the public interest because they exist predominantly to enable gambling through supposed ‘event contracts.’” 156 Cong. Rec. S5906–7 (2010). Rather than demonstrate intent to repeal federal gaming laws, this legislative history shows the exact opposite: Congress designed the Special Rule to prevent sports betting through supposed event contracts. As to IGRA’s criminal provisions, Congress likewise did not express a clear and manifest intent to repeal DOJ’s authority. In fact, Congress expressly disclaimed such a repeal in the text of the CEA. 7 U.S.C. § 16(e) (“Nothing in this chapter shall supersede or preempt . . . criminal prosecution under any Federal criminal statute.”). It is impossible for the CFTC to exercise exclusive jurisdiction over sports event contracts while the DOJ exercises its exclusive jurisdiction over criminal prosecutions of violations of state gambling laws made applicable by IGRA to Indian Country. The party arguing that two statues are irreconcilable bears the “heavy burden” of proving congressional intent to repeal. See Epic Sys. Corp. , 584 U.S. at 510. Kalshi cannot meet that heavy burden because there is a reasonable way to interpret the CEA that would give full effect to both statutes—sports event contracts are not “swaps” subject to the CFTC’s exclusive jurisdiction. Further,
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