2026 Membership Book FINAL

Case 1:25-cv-12578-RGS Document 1 Filed 09/15/25 Page 4 of 28

Massachusetts customers would also face abruptly losing access to sports-related event contract

trading through their Robinhood account.

6.

Robinhood therefore had no choice but to file this lawsuit to protect its

customers and its business. Robinhood respectfully requests that this Court enjoin Defendants

from enforcing preempted Massachusetts law against Robinhood for its facilitation of

transactions involving sports-related event contracts.

PARTIES

7.

Plaintiff Robinhood is a Delaware limited liability company with its

principal place of business in Chicago, Illinois. Robinhood is one of the family of companies

within the broader Robinhood organization. The Robinhood companies’ mission is to

democratize finance for all by removing barriers to access to financial markets. Robinhood is

registered with the Commodity Futures Trading Commission as a futures commission merchant

(“FCM”).

8.

Defendant Andrea Joy Campbell is sued in her official capacity as the

Attorney General of the Commonwealth of Massachusetts.

9.

Defendant Jordan Maynard is sued in his official capacity as the Chair of

the Massachusetts Gaming Commission.

10.

Defendant Eileen O’Brien is sued in her official capacity as Commissioner

of the Massachusetts Gaming Commission.

11.

Defendant Bradford R. Hill is sued in his official capacity as

Commissioner of the Massachusetts Gaming Commission.

12.

Defendant Nakisha Skinner is sued in her official capacity as

Commissioner of the Massachusetts Gaming Commission.

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