Case 1:25-cv-12578-RGS Document 1 Filed 09/15/25 Page 7 of 28
Commission (“CFTC”) as a futures commission merchant (“FCM”), which is an entity that
solicits or accepts orders to buy or sell futures and swaps and accepts payment from customers to
support such orders. See National Futures Association, Futures Commission Merchant (FCM)
Members, available at https://www.nfa.futures.org/members/fcm/index.html.
22.
Kalshi is a CFTC-designated contract market (“DCM”). See infra ¶¶ 27-
28. Kalshi offers many types of event contracts relating to a variety of areas including climate,
technology, health, cryptocurrencies, popular culture, economics and, as relevant here, event
contracts relating to the outcome of sporting events. Kalshi self-certified that its sports-related
event contracts comply with the CEA’s requirements and began listing them on January 24,
2025. Because the CFTC declined to review or prohibit Kalshi’s sports-related contracts, they
were deemed approved by the CFTC, became effective and are legal under federal law. See infra
¶¶ 29-31.
23.
On March 17, 2025, Robinhood launched its prediction markets hub,
through which its customers can place event contract trade orders. 1 Robinhood intermediates its
customers’ event contract trades, including sports-related event contract trades, on Kalshi’s
exchange. Robinhood has entered into agreements with Kalshi that allow it to access Kalshi’s
contract market facilities for this purpose. Those agreements obligate Robinhood to ensure such
access is secure and in compliance with all applicable laws, including the CEA and CFTC
regulations; they also require Robinhood to comply with Kalshi’s rules.
1 Robinhood began offering some limited event contract trading starting in October 2024, prior to the launch of the prediction markets hub. The only event contracts Robinhood offered in 2024 were related to the outcome of the U.S. presidential election; those contracts were not traded on Kalshi’s exchange.
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