2026 Membership Book FINAL

Case 1:25-cv-12578-RGS Document 1 Filed 09/15/25 Page 2 of 28

Commodity Futures Trading Commission (“CFTC”)-designated exchange. Thus, while

Robinhood’s approved customers can access event contracts trading through Robinhood’s

platform, all actual trades occur on Kalshi’s regulated exchange.

2.

On September 12, 2025, the Commonwealth of Massachusetts, by and

through its Attorney General, Andrea Joy Campbell, filed a lawsuit against Kalshi for allegedly

“offering sports wagering without a license in violation of G.L. c. 23N, § 5 et seq. ” Exhibit 1 ¶ 1

( Commonwealth of Massachusetts v. KalshiEx LLC , No. 2584CV02525, Dkt. 1 (Mass. Super.

Ct., Suffolk Cnty. Sept. 12, 2025) (hereinafter “ Massachusetts v. Kalshi ”)). Massachusetts seeks

monetary relief and a permanent injunction enjoining Kalshi “from engaging in sports wagering

without a license in violation of G.L. c. 23N.” Id. at 42. In its Complaint, Massachusetts

explicitly refers to Robinhood and its contractual relationship with Kalshi, alleging that “[t]he

availability of Kalshi’s contracts are not limited to Kalshi’s platform, but are also available on

Robinhood, a stock-trading platform accessible via app and webpage.” Id. ¶ 129. Massachusetts

further alleges that “[a]pproximately $1 billion worth of Kalshi wagers were traded on

Robinhood during the second quarter of the year, which likely generated an estimated $10

million in revenue for Kalshi.” Id. ¶ 130.

3.

Also on September 12, 2025, Massachusetts filed an Emergency Motion

for a Preliminary Injunction seeking to enjoin Kalshi from “engaging in any activity in

connection with sports wagering in the Commonwealth of Massachusetts” “until further order of

the Court.” Exhibit 2, Ex. A at 1-2 ( Commonwealth of Massachusetts v. KalshiEx LLC ,

No. 2584CV02525, Dkt. 4 (Mass. Super. Ct., Suffolk Cnty. Sept. 12, 2025)).

4.

However, as applied to trading on a CFTC-designated contract market,

Massachusetts law is preempted by the Commodity Exchange Act’s (“CEA”) comprehensive

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