Case 1:25-cv-14723 Document 1 Filed 08/19/25 Page 1 of 28 PageID: 1
UNITED STATES DISTRICT COURT DISTRICT OF NEW JERSEY
ROBINHOOD DERIVATIVES, LLC, Plaintiff, vs. MARY JO FLAHERTY, in her official capacity as Interim Director of the New Jersey Division of Gaming Enforcement; NEW JERSEY DIVISION OF GAMING ENFORCEMENT; and MATTHEW J. PLATKIN, in his official capacity as Attorney General of New Jersey, Defendants.
Case No.: COMPLAINT FOR PERMANENT INJUNCTION AND DECLARATORY RELIEF
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 1. 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”) 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 27, 2025, the New Jersey Division of Gaming Enforcement (“Division”) sent both Kalshi and Robinhood cease-and-desist letters from its Atlantic City
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