Case 1:25-cv-12578-RGS Document 1 Filed 09/15/25 Page 5 of 28
13.
Defendant Paul Brodeur is sued in his official capacity as Commissioner
of the Massachusetts Gaming Commission.
JURISDICTION AND VENUE
14.
This Court has subject matter jurisdiction over Robinhood’s claim
pursuant to 28 U.S.C. § 1331. This action presents a federal question under the Supremacy
Clause of the United States Constitution because it concerns whether Massachusetts laws are
preempted by the Commodity Exchange Act, 7 U.S.C. § 1 et seq. , to the extent they purport to
regulate trading on a CFTC-designated contract market.
15.
The Eleventh Amendment does not preclude this Court from exercising its
jurisdiction because it does not bar suits “[to] enjoin state officials to conform future conduct to
the requirements of federal law.” Town of Barnstable v. O’Connor , 786 F.3d 130, 138 (1st Cir.
2015) (alteration in original) (quoting Rosie D. ex rel. John D. v. Swift , 310 F.3d 230, 234 (1st
Cir. 2002)).
16.
This Court has personal jurisdiction over the Defendants. The Individual
Defendants are domiciled and perform their duties in Massachusetts. The Massachusetts
Gaming Commission maintains its principal place of business in this District.
17.
Venue is proper under 28 U.S.C. § 1391(b)(1) and (b)(2). The Individual
Defendants reside and perform their duties in this District. The Massachusetts Gaming
Commission’s office is in Boston. A substantial part of the events giving rise to Robinhood’s
claim occurred in this District.
RELEVANT FACTS
A.
Event Contracts
18.
An event contract is a type of derivative that allows customers to trade on
their predictions about the occurrence of future events. Event contracts are typically structured
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