2026 Membership Book FINAL

Case 1:25-cv-12578-RGS Document 1 Filed 09/15/25 Page 18 of 28

“conflicting regulatory requirements.” KalshiEx (D.N.J.) , 2025 WL 1218313, at *1; KalshiEx

(D. Nev.) , 2025 WL 1073495, at *6; see also Mallen v. Merrill Lynch, Pierce, Fenner & Smith,

Inc. , 605 F. Supp. 1105, 1112 (N.D. Ga. 1985) (“The congressional hearings focused on the need

for sole regulatory power of commodities to be placed in one federal agency, unlike the

regulation of securities which is shared by a federal agency and state agencies.”). Establishing

the CFTC and endowing it with exclusive jurisdiction was meant to “avoid unnecessary,

overlapping and duplicative regulation.” Ken Roberts Co. , 276 F.3d at 588 (quoting 120 Cong.

Rec. 34,736 (1974) (remarks of House Agriculture Committee Chairman Poage)); see also

120 Cong. Rec. 34,997 (1974) (remarks of Sen. Curtis on behalf of Sen. Talmadge); Senate

Hearings at 685 (statement of Sen. Clark) (“[D]ifferent State laws would just lead to total

chaos.”). Accordingly, the CFTC was empowered to set forth uniform rules and regulations for

“all exchanges and all persons in the industry.” H.R. Rep. No. 93-975, at 79 (1974).

Congressional statements concerning the event contract “special rule,” including by the drafters

of the Dodd-Frank Act of 2010, are consistent with these earlier statements and reveal clear

Congressional intent to vest exclusive jurisdiction over event contracts with the CFTC. See

Cong. Rec. S5906-07 (daily ed. July 15, 2010) (statements of Sen. Lincoln conveying her intent

and that of Sen. Dodd).

49.

As further indication of Congressional intent that the CEA preempt

broadly, during the amendment process for the 1974 amendments, the Senate considered adding

but ultimately did not include a provision that retained the states’ jurisdiction over futures

trading. See Kevin T. Van Wart, Preemption and the Commodity Exchange Act , 58 Chi.-Kent L.

Rev. 657, 687-88 (1982); see also 120 Cong. Rec. 30,464 (1974) (statements of Sens. Curtis and

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