Case 2:25-cv-01541-JCM-DJA Document 1 Filed 08/19/25 Page 2 of 26
official capacity as a Member of the Nevada Gaming Commission; BRIAN KROLICKI, in his official capacity as a Member of the Nevada Gaming Commission; GEORGE MARKANTONIS, in his official capacity as COMMISSION, a subdivision of the State of Nevada; AARON D. FORD, in his official capacity as Attorney General of Nevada, Defendants. a Member of the Nevada Gaming Commission; NEVADA GAMING
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Plaintiff Robinhood Derivatives, LLC (“Robinhood”), by its undersigned counsel, alleges, with knowledge with respect to its own acts and on information and belief as to other matters, as follows: NATURE OF THE ACTION Robinhood is a financial-services company that offers its approved customers the opportunity to trade, among other things, sports-related event contracts through the Robinhood platform. While Robinhood facilitates the placement and liquidation of event contracts for its customers, the contracts themselves trade on KalshiEx LLC’s (“Kalshi”) 1. Commodity Futures Trading Commission (“CFTC”)-designated exchange. Thus, while Robinhood’s approved customers can access event contracts trading through Robinhood’s platform, all actual trades occur on Kalshi’s regulated exchange. 2. On March 4, 2025, the Nevada Gaming Control Board (“Board”) sent Kalshi a cease-and-desist letter threatening to prohibit Kalshi from facilitating any trading of sports-related event contracts in Nevada. KalshiEx LLC v. Hendrick , No. 2:25-cv-00575-APG- BNW, ECF No. 1-2, at 2 (D. Nev. filed Apr. 9, 2025) (letter to Kalshi). The Board asserted that Nevada state gaming laws governed these transactions. Id. 3. Robinhood maintains that offering Kalshi’s sports-related event contracts to its customers in Nevada would not violate any state laws. But in light of the cease-and-desist letter that Kalshi received, as of March 14, 2025, Robinhood has not allowed Nevada residents to
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