IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MARYLAND
KALSHI EX LLC, Plaintiff, v.
Case No. 25-cv-1283-ABA
JOHN A. MARTIN, et al., Defendants.
BRIEF OF INDIAN GAMING ASSOCIATION, NATIONAL CONGRESS OF AMERICAN INDIANS, [ ] AS AMICI CURIAE IN SUPPORT OF DEFENDANTS 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. § 2702. The Indian Gaming Regulatory Act (“IGRA”) was enacted to provide a comprehensive regulatory framework for tribal government gaming intended to balance federal, tribal, and state interests. Amador County v. Salazar , 640 F3d 373, 376 (D.C. Cir. 2011); Chicken Ranch Rancheria of Me-Wuk Indians v. California , 42 F.4th 1024, 1031 (9th Cir. 2022). This delicate balance of federal, tribal, and state interests has allowed tribes to generate substantial gaming revenue, which goes directly to advance tribal self- sufficiency and fund important tribal government services that benefit tribal citizens. KalshiEX LLC’s (“Kalshi”) unlawful and unfair entrance into the gaming market has adversely impacted tribal gaming revenue and the benefit of tribes’ bargained-for compacts.
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