Case 1:25-cv-14723 Document 1 Filed 08/19/25 Page 4 of 28 PageID: 4
registered with the Commodity Futures Trading Commission as a futures commission merchant (“FCM”). 9. Defendant Mary Jo Flaherty is sued in her official capacity as the Interim Director of the New Jersey Division of Gaming Enforcement. 10. Defendant New Jersey Division of Gaming Enforcement is sued as the independent state agency within the New Jersey Attorney General’s office that, among other things, investigates violations of and enforces the New Jersey Casino Control Act, which regulates online gaming, sports wagering and the Atlantic City casinos. 11. Defendant Matthew J. Platkin is sued in his official capacity as Attorney General of New Jersey (together with Defendant Mary Jo Flaherty, the “Individual Defendants”). JURISDICTION AND VENUE 12. 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 New Jersey 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. 13. 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). 14. This Court has personal jurisdiction over the Defendants. The Individual Defendants are domiciled and perform their duties in New Jersey. The New Jersey Division of Gaming Enforcement maintains its principal place of business in this District.
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