Case 1:25-cv-14723 Document 1 Filed 08/19/25 Page 26 of 28 PageID: 26
threatened enforcement of New Jersey gambling laws is preempted by the CEA and the CFTC’s regulations pursuant to the Supremacy Clause. By threatening to enforce N.J.S.A. § 5:12A-11 and N.J. Const. art. IV, § 7, ¶ 2(D) 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. 68. 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 Division and the public would suffer little to no harm if the requested relief is granted. 69. To prevent further harm to Robinhood, the Court should enjoin Defendants from enforcing preempted New Jersey 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 N.J.S.A. § 5:12A-11, N.J. Const. art. IV, § 7, ¶ 2(D), and any other New Jersey law that attempts effectively to regulate Plaintiff’s involvement in transactions involving event contracts traded on a DCM;
ii.
Awarding a declaration that using N.J.S.A. § 5:12A-11, N.J. Const. art. IV, § 7, ¶ 2(D), and any other New Jersey law in a manner effectively
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