Case 2:25-cv-01541-JCM-DJA Document 1 Filed 08/19/25 Page 14 of 26
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that meeting, Board employees indicated they did not expect to be able to agree to refrain from enforcement action against Robinhood, even while the KalshiEx order is in place. They stated that they would contact Robinhood if they ultimately reached a different conclusion, and to date, they have not done so. 46. On May 8, 2025, the Board sent Robinhood a letter from its 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. This letter was signed by Kirk D. Hendrick, who at the time was Chairman of the Board and has since been replaced in that position by Defendant Dreitzer. Id. at 2. The letter copied Defendants Assad and Sendall in their positions as members of the Board, individuals in the Gaming Division of the Attorney General’s Office, and others. Id. The Board asserted that if Robinhood were to allow such trading, it would be in violation of the same Nevada laws as those it asserted Kalshi violated as well as Nev. Rev. Stat. § 463.350 (prohibiting persons under the age of 21 from being allowed to place wagers at sports pools). Id. The Board further stated that it would deem a decision by Robinhood to allow such trading to be “willful violations” of Nevada law, and it reserved the Board’s right to “pursue criminal and civil actions” should Robinhood allow its Nevada customers to trade sports-related event contracts. Id. Violations of the Nevada state gaming statutes cited in the Board’s letter are punishable as a “category B felony,” carrying a prison sentence of between one to ten years or a fine of up to $50,000. Nev. Rev. Stat. § 463.360(3). 47. 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. E. The CEA Preempts Application of State Gaming Laws to Sports-Related Event Contract Trading on CFTC-Designated Exchanges. 48. Transactions involving sports-related event contracts traded on Kalshi’s designated contract market—regardless of whether the orders come directly to Kalshi from
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