Case 1:25-cv-14723 Document 1 Filed 08/19/25 Page 3 of 28 PageID: 3
from enforcing similar Nevada laws against Kalshi for offering event contracts on its CFTC- designated exchange). 5. Despite those rulings, the Division continues to threaten to enforce preempted New Jersey law against Robinhood, even though the Division is currently enjoined by this Court from doing so against Kalshi with respect to the same transactions. 6. In light of this Court’s decision in KalshiEx , No. 25-cv-2152, 2025 WL 1218313, and the Division’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 New Jersey, Robinhood has reactivated its New Jersey 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 Division, along with the attendant reputational harm that any enforcement proceeding by the Division would cause. 7. Given the Division’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 New Jersey law against Robinhood for its facilitation of transactions involving sports-related event contracts. PARTIES 8. 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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