Case 1:25-cv-08846-AT Document 60-1 Filed 12/03/25 Page 29 of 31
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)). The revenue generated by tribal gaming supports thousands of jobs in hundreds of communities and provides critical funding to state and local governments through revenue-sharing agreements, tax revenue, and economic stimulus. If Kalshi 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 Kalshi’s motion for preliminary injunction. Dated this 3rd day of December, 2025.
Respectfully submitted, /s/ Joseph H. Webster
Joseph H. Webster ( pro hac vice pending) Elizabeth Bower ( pro hac vice forthcoming) Jens W. Camp ( pro hac vice pending) Hobbs, Straus, Dean & Walker LLP 1899 L Street NW, Ste. 1200 Washington, DC 20036 Telephone: (202) 822-8282 jwebster@hobbsstraus.com ebower@hobbsstraus.com jcamp@hobbsstraus.com /s/ Scott Crowell Scott Crowell ( pro hac vice pending) Crowell Law Office Tribal Advocacy Group PLLC 1487 W. State Route 89A, Suite 8 Sedona, AZ 86336
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