Case 2:25-cv-01541-JCM-DJA Document 1 Filed 08/19/25 Page 6 of 26
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authority on all licensing matters, retaining the power to approve, restrict, limit, condition, deny, revoke or suspend any gaming license. 20. Defendant Aaron D. Ford is sued in his official capacity as Attorney General of Nevada (together with Defendants Mike Dreitzer, George Assad, Chandeni K. Sendall, Jennifer Togliatti, Rosa Solis-Rainey, Brian Krolicki, George Markantonis and Abbi Silver, the “Individual Defendants”). JURISDICTION AND VENUE 21. This Court has subject matter jurisdiction over Robinhood’s claim pursuant to 28 U.S.C. § 1331. This action presents a federal question under the Supremacy Clause of the United States Constitution because it concerns whether Nevada laws are preempted by the Commodity Exchange Act, 7 U.S.C. § 1 et seq. , to the extent they purport to regulate trading on a CFTC-designated contract market. 22. The Eleventh Amendment does not preclude this Court from exercising its jurisdiction because it does not bar “suits against individual state officers for prospective injunctive and declaratory relief to end an ongoing violation of federal law.” Pa. Fed’n of Sportsmen’s Clubs, Inc. v. Hess , 297 F.3d 310, 323 (3d Cir. 2002). Further, the State of Nevada has waived sovereign immunity pursuant to Nev. Rev. Stat. § 41.031(2). 23. This Court has personal jurisdiction over the Defendants. The Individual Defendants are domiciled and perform their duties in Nevada. The Nevada Gaming Control Board and Nevada Gaming Commission maintain their principal places of business in this District. 24. Venue is proper under 28 U.S.C. § 1391(b)(1) and (b)(2). The Individual Defendants reside and perform their duties in this District. The Nevada Gaming Control Board has offices in Carson City, Las Vegas, Loughlin, Elko and Reno. The Nevada Gaming Commission has offices in Carson City. A substantial part of the events giving rise to Robinhood’s claim occurred in this District.
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