Case 2:25-cv-01541-JCM-DJA Document 1 Filed 08/19/25 Page 25 of 26
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regulations pursuant to the Supremacy Clause. By threatening to enforce Nev. Rev. Stat. §§ 463.160, 463.245, 463.350, 463.360, 465.086 and 465.092 against Robinhood for its involvement in transactions involving sports-related event contracts traded on a DCM, Defendants are intruding on the CFTC’s exclusive jurisdiction to regulate those transactions. 78. Robinhood has suffered and continues to suffer irreparable harm as a result of the Defendants’ actions and has no remedy at law to address the conduct complained of herein. The equities and public interest tilt strongly in Robinhood’s favor because without relief, the harm to Robinhood will be significant, and by contrast, the Board and the public would suffer little to no harm if the requested relief is granted. 79. To prevent further harm to Robinhood, the Court should enjoin Defendants from enforcing preempted Nevada law against Robinhood in contravention of the United States Constitution. PRAYER FOR RELIEF WHEREFORE, Plaintiff Robinhood respectfully requests that the Court enter judgment in favor of Robinhood and against Defendants: i. Issuing an injunction prohibiting Defendants and their officers, agents, servants, employees, and all persons in active concert or participation with them who receive actual notice of the injunction from enforcing against Plaintiff Nev. Rev. Stat. §§ 463.160, 463.245, 463.350, 463.360, 465.086, 465.092, and any other Nevada law that attempts effectively to regulate Plaintiff’s involvement in transactions involving event contracts traded on a DCM;
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ii.
Awarding a declaration that using Nev. Rev. Stat. §§ 463.160, 463.245, 463.350, 463.360, 465.086, 465.092, and any other Nevada law in a manner effectively to regulate Plaintiff’s involvement in transactions involving event contracts traded on a DCM violates the Supremacy Clause of the United States Constitution as applied to Plaintiff; and
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