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
2
Made with FlippingBook - Online catalogs