Case: 25-7187, 03/10/2026, DktEntry: 75.1, Page 11 of 43
The Amici Tribes are 19 federally recognized Indian Tribes within the meaning of the Indian Gaming Regulatory Act (“IGRA”). See 25 U.S.C. § 2703(5). Each of the Amici Tribes is a separate and distinct tribal government with the sovereign authority to conduct and regulate gaming activities on its Indian lands. The Amici Tribes all have a direct and immediate interest in maintaining their sovereign rights over gaming, including sports betting, on their Indian lands. Together, all the Tribal Amici have a shared, strong interest in this case because of its potential to significantly impact their or their member tribes’ sovereign rights regarding gaming on Indian lands, as well as Indian gaming and tribal governmental revenue as a whole. INTRODUCTION North American Derivatives Exchange Inc. d/b/a Crypto.com | Derivatives North America (“Crypto.com”) comes before this Court and asks it to wholly abandon the national policy of state and tribal sports-betting regulation and to turn decades of federal law on its head. The Court should not do so and, instead, affirm the district court’s decision. America’s history is replete with prospectors taking resources from Indian lands without permission from tribes. But Congress put a stop to that practice long ago. Yet Crypto.com would have this Court believe that, without so much as a whisper of legislative intent, Congress gave it permission to enter Indian lands and
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