2026 Membership Book FINAL

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

provision); Slaney v. Int’l Amateur Athletic Fed’n , 244 F.3d 580, 594-95 (7th Cir. 2001) (holding

that statute’s “exclusive jurisdiction” provision preempts state law claims).

42.

This express preemption provision includes event contracts, which are

“transactions involving swaps or contracts of sale of a commodity for future delivery,” over

which the CFTC has “exclusive jurisdiction” when “traded or executed on a [designated]

contract market.” 7 U.S.C. § 2(a)(1)(A). The term “swap” includes “any agreement, contract, or

transaction” that (among other things) “provides for any purchase, sale, payment, or delivery

(other than a dividend on an equity security) that is dependent on the occurrence, nonoccurrence,

or the extent of the occurrence of an event or contingency associated with a potential financial,

economic, or commercial consequence.” Id. § 1a(47)(A)(ii). The term “swap” was added to the

CEA in 2010 by the Dodd-Frank Act. See Pub. L. No. 111-203, §§ 721(a)(21) (adding the

definition of “swap” in 7 U.S.C. § 1a(47)), 722(a)(1)(D) (adding “swaps” to the exclusive

jurisdiction provision in 7 U.S.C. § 2(a)(1)), 124 Stat. 1376, 1666, 1672.

43.

Event contracts are transactions in a type of intangible commodity that the

CEA calls an “excluded commodity.” See United States v. Wilkinson , 986 F.3d 740, 745 (7th

Cir. 2021) (reviewing “excluded commodities” under the CEA). An “excluded commodity”

includes “an occurrence, extent of an occurrence, or contingency (other than [certain

exceptions]) that is (I) beyond the control of the parties to the relevant contract, agreement, or

transaction; and (II) associated with a financial, commercial, or economic consequence.” 7

U.S.C. § 1a(19)(iv).

44.

This is precisely what the event contracts traded on Kalshi’s exchange are.

Sports-related event contracts are within these statutory definitions of swaps and transactions in

excluded commodities because: (i) they are binary contracts that pay out depending on the

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