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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