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Case 1:25-cv-12578-RGS Document 1 Filed 09/15/25 Page 1 of 28

UNITED STATES DISTRICT COURT DISTRICT OF MASSACHUSETTS

ROBINHOOD DERIVATIVES, LLC,

Plaintiff,

vs.

ANDREA JOY CAMPBELL, in her official capacity as Attorney General of the Commonwealth of Massachusetts; JORDAN MAYNARD, in his official capacity as Chair of the Massachusetts Gaming Commission; EILEEN O’BRIEN, in her official capacity as Commissioner of the Massachusetts Gaming Commission; BRADFORD R. HILL, in his official capacity as Commissioner of the Massachusetts Gaming Commission; NAKISHA SKINNER, in her official capacity as Commissioner of the Massachusetts Gaming Commission; and PAUL BRODEUR, in his official capacity as Commissioner of the Massachusetts Gaming Commission,

Civil Action No.: 1:25-cv-12578

COMPLAINT FOR PERMANENT INJUNCTION AND DECLARATORY RELIEF

Defendants.

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”)

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