Case 2:25-cv-01541-JCM-DJA Document 1 Filed 08/19/25 Page 4 of 26
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6. On May 8, 2025, the Board sent Robinhood a letter, from the Board’s Las Vegas office, stating that it would consider Robinhood’s allowing Nevada customers to trade sports-related event contracts to be a violation of Nevada law. Exhibit 1, at 2 (letter to Robinhood). On May 19, 2025, Robinhood met with the Board again and sought an agreement from the State of Nevada to permit Robinhood at least temporarily to offer its customers the same sports-related event contracts that are traded on Kalshi’s exchange. The Board declined Robinhood’s proposal. 7. In light of this Court’s decision in KalshiEx , No. 2:25-CV-00575, 2025 WL 1073495, and the Board’s refusal to reach an agreement with Robinhood to mitigate the substantial ongoing economic and reputational harms Robinhood continues to suffer in the marketplace while Kalshi is permitted to trade sports-related event contracts in Nevada, Robinhood has activated its Nevada customers’ access to sports-related event contract trading. As a result, Robinhood now faces an immediate threat of civil penalties and criminal prosecution from the Board, along with the attendant reputational harm that any enforcement proceeding by the Board would cause. 8. Given the Board’s refusal to acknowledge what this Court has already held—that its threatened enforcement of state law is likely preempted by federal law— Robinhood had no choice but to file this lawsuit to protect its customers and its business. Robinhood respectfully requests that this Court enjoin Defendants from enforcing preempted Nevada law against Robinhood for its facilitation of transactions involving sports-related event contracts. PARTIES 9. Plaintiff Robinhood is a Delaware limited liability company with its principal place of business in Chicago, Illinois. Robinhood is one of the family of companies within the broader Robinhood organization. The Robinhood companies’ mission is to democratize finance for all by removing barriers to access to financial markets. Robinhood is
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